Blog Privacy Policy

The company “Pro Gamma S.p.A.”, with registered offices in Bologna, Italy, in Via D’Azeglio Nr. 51, tax code and VAT number 01985091204, is required to provide precise information about the processing of your personal data, pursuant to art. 13 of EU regulation 2016/679 “European regulation on the protection of personal data” (hereinafter “GDPR”) and Legislative Decree 196/2003 “Privacy Code”, regarding the rights due to those who write and wish to publish comments on the blog on the site www.instantdeveloper.com.

1. Data controller
The Data Controller, meaning the subject with decision-making authority over purposes of processing, methods of processing personal data, and the tools that will be used, is Pro Gamma SpA, with registered offices in Bologna, Italy in Via D’Azeglio Nr. 51, tax code and VAT number 01985091204, Tel. +39 051.538429 Fax: +39 051.6014132 – E-mail: privacy@instantdeveloper.com – Pec: amministrazione@pec.progamma.it.

2. Purposes of the processing / Legal basis for the processing
All data that you provide before, during, and after processing ceases are collected and used within the limits established by the law and the regulations regarding the processing of personal data, and are processed for the following purposes with the corresponding legal basis:

PURPOSES LEGAL BASIS
1. Purposes related to the publication of comments by users of the website www.instantdeveloper.com in the blog area contained herein. 1. The legal basis for the conferral of these data is the contract (or pre-contract) existing between the data subject and the Controller pursuant to point b) of article 6(1) of the GDPR, as well as the legitimate interests under point b) article 6(1) section F., to execute the user’s requests.

Processing of the data for these purposes is necessary for correctly managing the user’s comment request and their conferral is optional but necessary in order to carry out the purposes indicated above under item 1). Any refusal to provide your data will result in an inability to conduct the processing, conduct it correctly, or to fulfill potential legal obligations. In the event that the data you provide is incomplete or incorrect, the correctness of the processing cannot be guaranteed.

3. Categories of data processed
The processing concerns the following categories of data: first and last name, email address, for achieving the purposes of this processing.

4. Processing methods for Personal Data
Your data will be processed at the Controller’s premises (or if it should be necessary, at the premises of the subjects indicated in item 6) using paper and electronic instruments on the basis of principles strictly correlated with the purposes and in such a way as to ensure the security and confidentiality of those data. These instruments are organized in order to reduce to a minimum the risk of data distribution or loss, unauthorized access to them, or processing that is not compliant with the purposes described in this policy.
Your data are collected exclusively for the purposes described above. Said data are adequate, pertinent, complete, and do not exceed the purposes of the processing; if necessary, they may be updated to consistently ensure their accuracy. Please be advised also that no automated decision-making process concerning your information will be performed, and no profiling regarding your person will be done.

5. Data Storage Periods
Your information will be saved for the period necessary to execute the purposes indicated, save for the exercise of the rights listed below. In any case, the Controller and processors it designates may also store your data for an additional period solely for the purposes of fulfilling specific legal obligations, and upon the end of this period arrange for their deletion. The storage period is set at 10 years.

6. Categories of Subjects with which data may be shared or who may come to have knowledge of it as Processors or Appointed entities
For the pursuit of the purposes described above, your data will be processed by the Data Controller, the Processors they appoint, and those strictly authorized for processing.
Your data may be communicated for the sole purpose of fulfilling contractual or legal obligations:

  • Subjects whose authority to access the data is recognized by law, secondary legislation, and EC regulations;
  • Collaborators, employees, suppliers, sub-contractors, clients, and consultants of the Controller, in the area of their corresponding responsibilities and/or contractual obligations where applicable, including Processors and those Authorized;
  • Public Authorities and Administrations for fulfillment of legal obligations;
  • Outside parties who perform specific tasks on behalf of this company regarding legal, corporate, book-keeping, tax, and judicial requirements (this last in the event of litigation).

Your data are not subject to further circulation.

7. Transfer of Data to a Third Country
Your data can be processed with computer/electronic tools which could entail their processing in “Cloud Computing”, and in that case, they could be saved on servers located in countries outside the European Union. To that end, consent is requested from the data subject if there are no adequacy decisions or the transfer is not subject to sufficient guarantees. It is specified that if the data are processed using this technology, particularly stringent security measures will be used, and if the transfer must occur in third countries that have not been the object of adequacy decisions or if the transfer will not be subject to adequate guarantees, advance consent will be requested from the data subject.

8. Data subjects’ rights
Please be informed that the law assigns to you specific rights listed in art. 15 and ff of the GDPR, which you can exercise at any time, including: to know whether or not your personal data exist, and how they will be used; to request their deletion, anonymization, or to block data processed in violation of the law as well as that they be updated, rectified, or, where interested therein, integration of the data and to oppose the processing itself for legitimate reasons, as well as to oppose, in full or in part, for legitimate reasons, to the processing of personal data about you even if they are pertinent to the purpose of the collection, by contacting our Company, at the number +39 051.538429, or by fax to the number +39 051.6014132.
In any event requests under this section can be presented in writing via electronic mail sent to the address privacy@instantdeveloper.com, or via certified email (Pec) to the address amministrazione@pec.progamma,it, or by postal mail to: Company “Pro Gamma SpA” with registered offices in Italy, Bologna (BO) – 40123 – Via D’Azeglio # 51.
You will always have the right to submit a complaint with the Italian Privacy Authority, located in Piazza Venezia # 111 – 00186 Rome (RM), Italy – Tel. +39 06 696771 – Email: garante@gpdp.it – Certified email: protocollo@pec.gpdp.it.

We also inform you that the company Pro Gamma SpA has arranged for the nomination of the DPO – Data Protection Officer – the individual with whom you can exercise your rights, as well as ask any question regarding the protection of personal data, with the following contact information: Via De Gasperi # 5 – 48121 – Ravenna (RA), Italy, email: dpo@instantdeveloper.com, pec: gcrocetti@pec.it.