Privacy policy - Newsletter

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 sign up for the Newsletter service 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 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. Newsletter Service: to provide a service exclusively upon explicit request from the user, of an informative, promotional, and commercial nature, concerning the services provided by the Controller 1. The legal basis for the processing lies in the user’s explicit consent, given when providing the data and subscribing to the service (art. 6(a) – GDPR 679/2016).

Providing data is optional, but it is required for implementation of the purposes set forth above. Any refusal to provide your data will result in a failure to establish or continue the service or conduct it correctly. 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

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6. Categories of Subjects with which data may be shared or who may come to have knowledge of it as Processors or Appointed entities

In order to pursue the purposes described above, your personal data will be processed by the Data Controller, by the Processors, and those nominated as authorized for processing.
Your data may be communicated, for the sole purpose of fulfilling contractual or legal obligations, to:

  • 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. It is specified that in the latter case, data transfer occurs by virtue of a European Commission decision regarding the suitability of the level of data protection in the extra-EU country or on the basis of the appropriate guarantees envisaged under art.s 46 or 47 of the GDPR (e.g., signing “standard clauses” for data protection adopted by the European Commission) or further conditions of legitimacy of the transfer envisaged in art. 49 of the GDPR (e.g., execution of the requested or extant contract, consent).

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.
In any case, 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: dpo@instantdeveloper.com, pec: gcrocetti@pec.it.