1. DEFINITIONS
1.1. ADMINISTRATOR – UKEG GROUP S.r.l., in the person of the pro tempore legal representative based in Venice-Mestre, piazzale Leonardo da Vinci 8/A, Tax Code and VAT No. 04207510241.
1.2. PERSONAL DATA – All information on the natural person identified or identifiable through one or more characteristic aspects that can define the physical, physiological, genetic, psychic, economic, cultural or social identity, including the IP of the device, the localization data, web identifier and information collected through cookie files and other similar technologies.
1.3. PRIVACY POLICY – This Privacy Policy.
1.4. GDPR – Regulation of the European Parliament and of the Council (EU) 2016/679, of the 27th April 2016, concerning the protection of individuals with regard to the processing of personal data, as well as the free circulation of such data and repealing Directive 95/45 /EC.
1.5. SERVICE – Web service managed by the Administrator at www.ukeg.it.
1.6. USER – Any natural person who visits the service or uses one or more services or features governed by this privacy policy.
2. DATA PROCESSING IN RELATION TO THE USE OF THE SERVICE
2.1. In relation to the use of the Service by the User, the Administrator collects data for the purpose of providing the various services offered and the information relevant to the User’s activity in the Service. The detailed rules and goals of the data processed during the use of the Service are described hereinafter.
3. TARGETS AND REFERENCE STANDARDS FOR DATA PROCESSING WITHIN THE SERVICE
USE OF THE SERVICE
3.1. The personal data of all the subjects who use the Service (including the IP address or other identifiers, as well as the information collected by cookie files of other similar technologies) and who are not registered Users (i.e. subjects who do not have a profile within the Service) are processed by the Administrator.
3.1.1. For the purposes of providing electronic services and making the Service content available to the User. In this case, the processing is essential for the execution of the contract (Article 6, paragraph 1, letter B, GDPR).
3.1.2. For analytical and statistical purposes, in this case the processing is necessary for pursuing the legitimate interest of the Administrator (Article 6, paragraph 1, letter F, GDPR), consisting in the execution of an analysis of the Users’ activity and their preferences with the aim of correcting the functionalities applied and the services provided.
3.1.3. For the purposes of the possible definition and exercise of claims or the defense against them. The processing is based on the legitimate interest of the Administrator (Article 6, paragraph 1, letter F, GDPR), consisting of the protection of his rights.
3.1.4. For marketing purposes, by the Administrator and other parties, with particular reference to behavioral advertising. The rules for the processing of personal data for marketing purposes are described in the “MARKETING” section.
3.2. The User’s activity within the Service, including his/her personal data, is recorded in the system logs (special computer software used for storing the chronological records with information on events and operations relating to the computer system, used by the Administrator for the provision of services). The information collected in the logs are mainly processed for purposes related to the provision of services. The Administrator also processes the data for technical and administrative purposes, for ensuring the security of the computer system and for managing the IT system, as well as for analytical and statistical purposes. In this case, the processing is based on the legitimate interest of the Administrator (Article 6, paragraph 1, letter F, GDPR).
3.3. In the event that the User introduces, within the Service, any personal data of other subjects (including name and surname, address, telephone number or e-mail address), he is allowed to do it, provided that he does not breach the laws in force and the personal assets of these subjects.
CONTACT FORMS
3.4. The Administrator guarantees the possibility of contact by using the electronic contact form. The use of this form involves the need to provide the personal data necessary to contact the User and answer to the question submitted. The User can also provide other data to facilitate the contact or the fulfillment of his/her request. The submission of the data indicated as mandatory is required for managing the application. Failure to submit the data will make it impossible to manage the application. The other data will be provided voluntarily.
3.5. Personal data are processed:
3.5.1. for the purpose of indicating the sender and for the management of the request submitted through the form (including the preparation of an offer/quote) – in this case, the processing is considered essential for the execution of the service provision contract (art. 6, paragraph 1, letter B, GDPR);
3.5.2. for the purpose of carrying out surveys to control the quality of the service. In this case, the processing is based on the Administrator’s legitimate interest of the Administrator (Article 6, paragraph 1, letter F, GDPR), which consists of the collection of information regarding the User’s satisfaction for the services provided;
3.5.3. with analytical and statistical purposes. In this case, the processing is necessary for pursuing the Administrator’s legitimate interest (Article 6, paragraph 1, letter F, GDPR), which consists of keeping of statistics relevant to the requests submitted by Users through the Service, so such as to refine the Service functionality and define the purchase preferences;
3.5.4. to send the Administrator’s marketing content to Users. The processing is based on the Administrator’s legitimate interest (Article 6, paragraph 1, letter F, GDPR);
3.5.5. to send Users the marketing content of partners and subjects characterized by capital, organizational and personal obligations with the Administrator. The treatment is based on the User’s consent (Article 6, paragraph 1, letter A, GDPR);
3.5.6. for the purposes of the possible definition and exercise of claims or defense from them. The processing is based on the Administrator’s legitimate interest (Article 6, paragraph 1, letter F, GDPR), consisting of the protection of his rights.
4. MARKETING
4.1. The Administrator processes the personal data of Users with the aim of carrying out marketing operations.
These operations may consist of the following:
4.1.1. The display of marketing content intended for the User, adapted to his preferences (contextual advertising).
4.1.2. the display of marketing content intended for the User, adapted to his interests (behavioral advertising);
4.1.3. Sending e-mails about promotions or interesting contents, characterized by the presence, in some cases, of commercial information (newsletter service);
4.1.4. The execution of other types of operations, related to the direct marketing of goods and services (sending commercial information electronically and telemarketing operations);
4.2. For carrying out marketing operations, the Administrator, in some cases, uses profiling. This means that, thanks to the automatic processing of data, the Administrator performs the evaluation of factors chosen, relating to natural persons, for the purpose of analyzing their behavior or making forecasts for the future.
CONTEXTUAL ADVERTISING
4.3. The Administrator processes the personal data of Users for marketing purposes in relation to the sending of contextual advertising (i.e. advertising adapted to the User’s preferences). The processing of personal data takes place exclusively in relation to the realization of the legitimate interest of the Administrator (Article 6, paragraph 1, letter F, GDPR).
BEHAVIORAL ADVERTISING
4.4. The Administrator and its trusted partners process the User’s personal data, including personal data collected by means of cookies and other similar technologies, for marketing purposes and for sending behavioral advertising (advertising adapted to the User’s preferences). The processing of personal data, in this case, also includes the Users’ profiling. The use of personal data collected for marketing purposes by means of this technology, including the promotion of services and goods of third parties, requires the User’s consent. This consent can be withdrawn at any time.
NEWSLETTER
4.5. The Administrator provides the newsletter service, as defined in the regulation, to subjects who have provided their e-mail address for this purpose and have given their consent to receive the newsletter. The transmission of data is required for the purpose of providing the newsletter service, and failure to transmit it makes it impossible to send newsletters.
4.6. Personal data are processed:
4.6.1. for the purpose of sending newsletters. The processing, in this case, is necessary for the purpose of executing the contract (Article 6, paragraph 1, letter B, GDPR);
4.6.2. to send the marketing content in the newsletter. The processing, complete profiling, is based on the Administrator’s legitimate interest (Article 6, paragraph 1, letter F, GDPR), in relation to the expression of consent to receive the newsletter;
4.6.3. with analytical and statistical purposes. In this case, the processing is necessary for pursuing the Administrator’s legitimate interest (Article 6, paragraph 1, letter F, GDPR), consisting in the execution of analysis of the Users’ activity and their preferences, with the aim to correct the applied functionalities;
4.6.4. for the purposes of the possible definition and exercise of claims or defense from them. The processing is based on the Administrator’s legitimate interest (Article 6 paragraph 1 letter F GDPR).
DIRECT MARKETING
4.7. The User’s personal data may also be used by the Administrator for the purpose of sending marketing content to the User by means of various channels (e.g. via e-mail, MMS/SMS, WhatsApp or by phone). These operations are carried out by the Administrator only if the User gives his consent (this consent can be withdrawn at any time).
5. SOCIAL NETWORK
5.1. The Administrator processes the personal data of Users who visit the Administrator’s profiles in the social networks (for example Facebook, You Tube, Instagram, Twitter). These data are processed only in relation to the profile management as well as for informing the Users about the Administrator’s activities and promoting various types of events, services and products. In this case, Administrator’s personal data processing is based on his legitimate interest (Article 6, paragraph 1, letter F, GDPR) which consists of the promotion of his own brand.