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PRIVACY

NOTICE ON THE PROCESSING OF PERSONAL DATA

pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR)

Website

Version 2024

This notice is provided in accordance with Article 13 of Regulation (EU) 2016/679 (the General Data Protection Regulation, hereinafter “GDPR”) and describes how the personal data of visitors/users who consult the website of PHSE S.R.L. (hereinafter, the “Data Controller”, “Controller” or “PHSE”) accessible online at http://www.airplus.it/.

  1. DATA CONTROLLER

1.1. The Data Controller is PHSE S.R.L., with registered office at Via Del Lavoro snc, p. T-S1, Località Cà dei Bolli, 26817 San Martino in Strada (LO), VAT No. 04176351213.

1.2. 1.2. Contact details: Telephone: 081 53941; Certified email: phse@pec.com, Email: info.it@phse.com.

  1. DATA PROTECTION OFFICER

2.1. Il responsabile della protezione dei dati, che potrà essere contattato per tutte le questioni relative al trattamento dei dati personali e all’esercizio dei diritti derivanti dalla GDPR, è disponibile ai seguenti recapiti: a) telefono: 055750808; b) e-mail: dpo.sicurdata@opendata.it.

  1. PERSONAL DATA PROCESSED, PURPOSES OF PROCESSING, LEGAL BASIS, NATURE OF PROVISION AND RETENTION PERIOD

3.1. 3.1. In this section, for each purpose, you will be informed of the personal data processed, the legal basis for processing, the nature of the provision and the retention period.

  1. Website browsing. Personal data processed: personal data transmitted implicitly during the use of internet communication protocols (IP addresses, domain names of the computers used to connect to the site, URI addresses – Uniform Resource Identifier – of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response to the server and other parameters relating to the user’s operating system and IT environment). Purpose: to enable browsing and consultation of the website. Legal basis: Article 6(1)(f) of the GDPR, as the processing is necessary for the purposes of the data controller’s legitimate interests. Nature of provision: necessary in order to browse the website. Retention period: for the entire duration of the browsing session in relation to the data collected during the session and for a maximum period of seven (7) days, subject to a further period should this be necessary to establish liability for any cybercrimes.
  2. Requests for assistance or information. Personal data processed: first name, surname, email address, telephone number and any other information you may voluntarily provide to us, in addition to data relating to your browsing of the website. Purpose: to respond to requests for assistance or information received via email, telephone, chat or the dedicated form. Legal basis: Article 6(1)(b) of the GDPR, as the processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the data subject’s request. Nature of provision: necessary in order to make requests for assistance or information. Retention period: for as long as necessary to respond to your requests for assistance or information and, in any event, for a maximum period of one year once we have responded to your requests.
  3. Provision of services. Personal data processed: identification data and data necessary for the processing and completion of the requested services, including first name, surname, residential address, email address, telephone number and other information that may be necessary to fulfil the provision of the service. Purposes: provision of services and communication relating to the performance of the established relationship. Legal basis: Article 6(1)(b) of the GDPR, as it is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the data subject’s request. Nature of provision: necessary in order to use the requested services. Retention period: ten (10) years from the provision of the service for administrative and accounting purposes.
  4. Legal obligations. Personal data processed: the same data collected during the purchase of products and services and their delivery/provision. Purpose: to fulfil legal, accounting and tax obligations related to the provision of services. Legal basis: Article 6(1)(c) of the GDPR, as it is necessary to comply with a legal obligation to which the data controller is subject. Nature of provision: necessary to enable proper accounting and administrative management. Retention period: ten (10) years from the provision of the service for administrative and accounting purposes.
  5. Customer Satisfaction. Personal data processed: first name, surname, email address and telephone number. Purpose: to carry out studies, research and market statistics; to send you advertising, informational and commercial material or surveys to improve the service (“customer satisfaction”) via email or text message, and/or via telephone with an operator and/or through PHSE’s official social media pages. Legal basis: your consent pursuant to Article 6(1)(a) of the GDPR. You may withdraw your consent at any time by writing to one of the addresses provided in this notice. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to withdrawal. Nature of provision: optional, and does not affect other processing purposes. Retention period: until you withdraw your consent.
  6. Marketing. Personal data processed: first name, surname, email address and telephone number. Purpose: to make personalised commercial offers based on the products or services you have purchased, or in which you have shown an interest whilst browsing our website. Legal basis: your consent pursuant to Article 6(1)(a) of the GDPR. You may withdraw your consent at any time by writing to one of the addresses provided in this policy. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to withdrawal. Nature of provision: optional, and does not affect other processing purposes. Retention period: until you withdraw your consent.
  7. Fraud prevention. Personal data processed: behaviour on the website, including IP addresses. Purpose: security and prevention of fraudulent conduct, for which the data controller uses an automated monitoring system involving the detection and analysis of user behaviour on the website associated with the processing of personal data, including the IP address. Legal basis: Article 6(1)(f) of the GDPR, as the processing is necessary for the pursuit of the data controller’s legitimate interests. Nature of provision: necessary in order to browse the website. Retention period: seven (7) days, unless an anomaly occurs. In such a case, the data will be retained until the behaviour has been ascertained and, in the event of legal proceedings, until the conclusion of such proceedings.

3.2. With regard to cookies, please refer to the cookie policy available on this website.

3.3. 3.3. Your personal data may be processed, where necessary and following its provision for the purposes set out above, to establish, exercise or defend a legal claim, on the basis of the data controller’s legitimate interest (Article 6(1)(f) of the GDPR).

  1. RECIPIENTS OF THE DATA.

4.1. 4.1. The data processed will not be disclosed to third parties, except in cases provided for by law.

4.2. 4.2. In order to provide the requested services, the data controller may entrust your personal data to various service providers, with whom it has entered into a specific contract designed to protect your personal data and comply with data protection legislation. These are entities identified as data processors pursuant to Article 28 of the GDPR to whom the data controller has entrusted, including but not limited to, the following services: i) individuals, companies or professional firms providing assistance and consultancy to PHSE in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services; ii) parties with whom it is necessary to interact for the provision of the Services; iii) or parties delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communications networks).

4.3. 4.3. The data controller may disclose your personal data to parties, bodies or authorities to whom such disclosure is mandatory under the law or by order of the authorities. Such parties will act as independent data controllers.

4.4. 4.4. Your personal data may be processed by persons authorised by PHSE pursuant to Article 29 of the GDPR, who have undertaken to maintain confidentiality or are subject to an appropriate legal obligation of confidentiality, such as the Data Controller’s employees.

4.5. 4.5. The full list of data processors is available upon request to the data controller at one of the contact points indicated in this notice.

  1. DATA TRANSFER

5.1. 5.1. Some of your Personal Data is shared with Recipients who may be located outside the European Economic Area, including offices in the UK and Singapore. PHSE Srl ensures that the processing of your Personal Data by these Recipients takes place in accordance with the Regulation ( ). Indeed, transfers may be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission.

  1. RIGHTS OF THE DATA SUBJECT

6.1. 6.1. With regard to the data itself, the data subject, or a person delegated in writing, may exercise the following rights, including by writing to the data controller’s contact points indicated in this notice: a) the right of access pursuant to Article 15 of the GDPR; b) the right to rectification pursuant to Article 16 of the GDPR; c) the right to be forgotten pursuant to Article 17 of the GDPR; d) the right to restriction of processing where one of the circumstances provided for in Article 18 of the GDPR applies; e) the right to receive confirmation that the actions taken pursuant to Articles 16, 17 and 18 of the GDPR have been brought to the attention of those to whom the data have been disclosed, unless this proves impossible or involves a disproportionate effort (Article 19 of the GDPR); f) the right to data portability pursuant to Article 20 of the GDPR; f) the right to object to the processing of personal data pursuant to Article 21 of the GDPR; g) the right not to be subject to a decision based solely on automated processing pursuant to Article 22 of the GDPR; g) the right to withdraw consent at any time pursuant to Article 7 of the GDPR.

6.2. 6.2. You have the right to lodge a complaint with a supervisory authority, in accordance with Article 77 of the GDPR.

6.3. 6.3. To exercise your rights, you may contact the data controller or the data protection officer at the contact details provided in this notice.

  1. FURTHER INFORMATION

7.1. 7.1. The data controller remains available to provide any necessary clarification and, should the processing be modified from that described in this document, the data controller will provide an updated privacy notice.

7.2. 7.2. The protection of your personal data and compliance with the principles set out in the legislation, with particular reference to the principle of transparency, are of paramount importance to us. We would be grateful if you could assist us by reporting any misunderstandings regarding this document or by suggesting improvements via the data controller’s contact details as indicated above.

[ ] I have read the privacy policy

[ ] I consent to the processing of my personal data for Customer Satisfaction purposes

[ ] I consent to the processing of my personal data for Marketing purposes