Calypso privacy policy

SuexS.r.l thanks you for the interest in this app, pursuant to and for the purposes of article 13 of Regulation (EU) 2016/679 (General Data Protection Regulation - G.D.P.R.) “on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)” we inform you of the following.
For information about your collected personal data, the purposes and the parties with whom the data is shared, contact the Data Controller.
Definitions
Personal Data
Personal data is any information that, directly or indirectly, in conjunction with any other information, including a personal identification number, can identify a natural person or make them identifiable.
Users
The individual, who uses this Application, unless otherwise stated, coincides with the Interested Party.
Interested Party
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller, as set out in this privacy policy. Data Controller (or Controller)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including security measures related to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
This Application
The hardware or software tool through which the Users’ Personal Data are collected and processed.
Service
The Service provided by this Application as defined in relative terms (if any) on this site / application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.
Data Controller
The Data Controller is SuexS.r.l. (hereinafter the “Data Controller”) and can be contacted by written notice to be sent to: SuexS.r.l., Via Roma 261/35, 31020 Villorba (TV) – Italia or by e-mail: info@suex.it.
The Data Protection Officer, appointed by the Data Controller can be contacted using the following methods: info@suex.it.
The updated list of the officers appointed by the Data Controller pursuant to article 28 of the aforementioned EU Regulation and of the persons authorized to process it can be consulted at the SuexS.r.l. headquarters.
Type of Data processed
The collected Personal Data is processed in order to allow access to the services provided and are strictly necessary for the supply, it is information relating to: - individual user identification data; - use of the app data or information automatically collected by this Application (also by third-party applications integrated in this Application), including: the IP addresses or domain names of the computers used by the User that connect to this Application, the addresses in URI (Uniform Resource Identifier), the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the state of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment; - technical data such as opt-out declarations relating to advertising campaigns, downloads, impressions, clicks and app installations, behavior within the app or information on the operating system of the device in use, device setting parameters, device speed, device information and settings; - user geolocation data, such as device coordinates, device speed and travel data.
Complete details of each type of collected data are provided in the dedicated sections of the privacy policy or through specific informative texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, Geolocation Data or Technical Data, collected automatically during the use of this Application.
Unless otherwise specified, all the Data requested by this Application is obligatory. If the User refuses to release the Data, it may be impossible for this Application to provide the Service. Where this Application indicates Data as optional, Users are free to refrain from giving such Data, without having any consequence on the availability of the Service or its operation.
The possible use of Cookies – or other tracking tools – by this Application or third party service providers used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy, if available.
The User assumes the responsibility for the Personal Data of third parties obtained, published or shared through this Application and declares to have the right to communicate or broadcast them, thus relieving the Data Controller of all responsibility towards third parties.
Mode and place of processing the Data
Methods of processing
The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Data Controller. The updated list of these parties may be requested from the Data Controller at any time.
Legal basis for processing personal data
The Data Controller may process Personal Data relating to Users if one of the following applies: • processing is necessary for the execution of a contract with the User and/ or for the execution of pre-contractual measures connected to the service provided by the Application;
• processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
• processing is necessary for the execution of a public interest task or for the exercise of public powers vested in the Data Controller;
• processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties;
• processing is necessary in the presence of specific consent, for marketing purposes (sending e-mails, SMS, newsletters to promote products or services offered by the Data Controller), for direct sales purposes, as well as for sending market research and to verify the degree of user satisfaction;
• processing is necessary to communicate and transfer the User’s data to third parties, in the event that they have expressed their consent and up to revocation of said consent, for sending commercial communications on products and their services, also with automated methods;
• processing is necessary to carry out, in the event that they have expressed their consent and up to revocation of said consent, also through electronic tools, analysis of specific behaviors and consumption habits, so as to improve the services provided and direct the commercial proposals in question, by also offering third parties the aggregated summary data of the openings and clicks obtained through a tracking system using cookie policy.

You can always request the Data Controller to clarify the concrete legal basis of each process and in particular, to specify whether the process is based on the law, provided by a contract or necessary to conclude a contract.
The Personal Data sent may be processed by the Data Controller with automated tools. Notwithstanding, the possibility remains SuexS.r.l. to process the aforementioned Data in aggregate form, in compliance with the measures prescribed by the Antitrust Authority and by virtue of the specific exemption from the consent provided for by the same, for analysis and electronic processing (e.g.: classification of the entire clientele in homogeneous categories by service level, consumption, expense, etc.) aimed at periodically monitoring the development and economic performance of the activities of SuexS.r.l., to direct the relative industrial and commercial processes, as well as to plan and implement commercial communication partners.
The processing of Personal Data provided may also be carried out by companies, organizations or consortia, appointed as data processors pursuant to article 28 of the aforementioned EU Regulation, which, on behalf of SuexS.r.l., provide specific processing services, or committed, instrumental or support activities.
Place
The Data are processed at the Data Controller's operating offices, on electronic databases located in Italy, in countries belonging to the European Economic Area (EEA) and in third countries that guarantee an adequate level of data protection. For more information, contact the Data Controller.
In the event of greater protection, the User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to international bodies of public international law or constituted by two or more countries, as well as regarding the security measures adopted by the Data Controller to protect the Data.
If one of the transfers described above takes place, the User may refer to the respective sections of this document or request information by contacting the Data Controller from the information provided above.
Retention time
The Data is processed and stored for the time required for the purposes for which it was collected.
Therefore: • Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User shall be retained until such contract has been fully performed
• Personal Data collected for the purposes of the Data Controller’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Data Controller within the relevant sections of this document or by contacting the Data controller.

The Data Controller may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
User rights
Users may exercise certain rights regarding their Data processed by the Data Controller.
In case of greater protection, the User can exercise all the rights listed below. In any other case, the User can contact the Data Controller to find out what rights are applicable in their case and how to exercise them.
In particular, Users have the right to do the following: • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. Such revocation will not affect the lawfulness of the processing based on consent before the revocation.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. In accordance with article 15 G.D.P.R. Users have the right to learn if Data is being processed by the Data Controller, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. The right of access may be limited in certain circumstances to protect the interests of other parties, as it is not an absolute right. In the event of a request for copies, administrative costs incurred may be charged with a request for a reasonable fee.
• Verify and seek rectification. In accordance with article 16 G.D.P.R. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. In accordance with article 18 G.D.P.R. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Data Controller will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. In accordance with article 17 G.D.P.R., Users have the right, under certain circumstances, to obtain the erasure of their Data from the Data Controller.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority in accordance with article 77 of EU Regulation 2016/679 or engage in legal proceedings.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Data Controller or for the purposes of the legitimate interests pursued by the Data Controller, Users may object to such processing by providing grounds related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Data Controller is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Data Controller through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Data Controller as early as possible and always within one month.
Applicability of greater protection
While most of the provisions of this document apply to all Users, some are expressly subject to the applicability of greater protection to the processing of Personal Data.
This greater protection is always guaranteed when the treatment: • is performed by a Data Controller located in the EU; or
• concerns Personal Data of Users located in the EU and is functional to the supply of goods or services for consideration or free of charge to such Users; or
• concerns Personal Data of Users located in the EU and allows the Data Controller to monitor the behavior of these Users to the extent that such behavior takes place within the Union.

Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Data Controller in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Data Controller may be required to reveal Personal Data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operational and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs), that is files that record the interactions and that may also contain Personal Data, such as the IP address of the User.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Data Controller. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Data Controller shall collect new consent from the User, where required.
Last modification February 2019