Impressum & data protection
responsible
NAME
Monte Paraccia
Straße X
04275 XXX
italy
email:Site:
Disclaimer: Despite careful content control, we assume no liability for the content of external links. Only their operators are responsible for the content of the linked pages.
GDPR - Privacy Policy
In principle, it is possible to use our Internet pages without providing any personal data. However, if a data subject wishes to make use of special services via our website (contact form), it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the person concerned.
The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in line with the General Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to us. By means of this privacy policy, we would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of the rights they are entitled to by means of this privacy policy.
As data controller, we have implemented numerous technical and organizational measures to ensure that personal data processed via this website is protected as completely as possible. However, Internet-based data transmissions can generally have security gaps, meaning that absolute protection cannot be guaranteed. For this reason, every data subject is also free to transmit personal data to us by alternative means, for example by e-mail or post.
1. Definitions
Our privacy policy is based on the terms used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand both for the public and for our customers and business partners. To ensure this, we would like to explain the terms used in advance.
In this privacy statement, we use the following terms, among others:
a) Personal data
Personal data is any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more particular characteristics that are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person whose personal data is processed by the controller.
c) Processing
Processing is any process carried out with or without the aid of automated processes or any such series of processes in connection with personal data, such as collecting, organizing, storing, adapting or modifying, reading, querying, using, disclosing through transmission, dissemination or any other form of provision, reconciliation or linking, restriction, deletion or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of restricting their future processing.
e) Profiling
Profiling is any type of automated processing of personal data that consists of using this personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or changes of location of that natural person.
f) Pseudonymization
Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is stored separately and is subject to technical and organizational measures which ensure that the personal data is not assigned to an identified or identifiable natural person.
g) Responsible for processing
Responsible for processing is the natural or legal person, authority, agency or other body which alone or together with others decides on the purposes and means of processing personal data (in this case: we, Trafo e.V.). If the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or the specific criteria for its nomination may be provided for under Union law or the law of the Member States.
h) Contract processor
Contract processor is a natural or legal person, authority, agency or other body that processes personal data on behalf of the person responsible.
i) Recipient
The recipient is a natural or legal person, authority, institution or other body to which personal data is disclosed, regardless of whether it is a third party or not. However, public authorities that may receive personal data as part of a specific investigation mandate under Union or Member State law are not considered recipients.
j) Third party
A third party is a natural or legal person, authority, agency or body other than the data subject, the controller, the processor and the persons who, under the direct responsibility of the controller or processor, are authorized to process personal data.
k) Consent
Consent is any expression of will given voluntarily by the data subject in an informed and unequivocal manner in the form of a statement or other unequivocal affirmative action by which the data subject indicates that he or she agrees to the processing of personal data concerning him or her.
2. Responsible for processing
Responsible person within the meaning of the General Data Protection Regulation, other data protection laws applicable in member states of the European Union and other provisions related to data protection law is:
Monte Paraccia
Straße X
04275 XXX
italy
email:Site:
3. Collection of general data and information
Our website collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server's log files. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and Information that serves to avert threats in the event of attacks on our information technology systems.
When using this general data and information, we do not draw any conclusions about the data subject. Rather, this information is required to (1) correctly deliver the content of our website, (2) to ensure the long-term functionality of our information technology systems and the technology of our website, and (3) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. We therefore analyse this anonymously collected data and information statistically on the one hand and also with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.
4. Contact options via the website
Due to legal regulations, our website contains information that enables quick electronic contact with us and direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts us by email or via a contact form, the personal data provided by the data subject is automatically stored. Such personal data provided to us on a voluntary basis by a data subject is stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
5. Routine deletion and blocking of personal data
We process and store personal data of the data subject only for the period necessary to achieve the storage purpose or if this has been provided for by the European legislator or another legislator in laws or regulations to which we are subject.
If the storage purpose ceases to apply or if a storage period prescribed by the European legislator of directives and regulations or another competent legislator expires, the personal data will be blocked or deleted routinely and in accordance with legal requirements.
6. Rights of the person concerned
a) Right to confirmation
Every data subject has the right granted by the European legislator of directives and regulations to request confirmation from us as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right of confirmation, they can contact us at any time.
b) Right to information
Every person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to receive information from us free of charge about the personal data stored about him and a copy of this information at any time. In addition, the European legislator has provided the data subject with information on the following information:
- the purposes of processing,
- the categories of personal data that are processed
- the recipients or categories of recipients to whom the personal data have been or are still being disclosed, in particular recipients in third countries or international organizations,
- if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this period,
- the existence of a right to correct or delete personal data concerning you or to restrict processing by us or a right to object to this processing,
- the existence of a right to lodge a complaint with a supervisory authority,
- if the personal data is not collected from the data subject: all available information about the origin of the data,
- the existence of automated decision-making, including profiling, in accordance with Article 22 (1) and (4) GDPR and — at least in these cases — meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
In addition, the data subject has the right to information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate guarantees in connection with the transfer.
If a data subject wishes to exercise this right of information, they can contact us at any time.
c) Right to rectification
Every person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to request the immediate correction of incorrect personal data concerning him or her. In addition, the data subject has the right, taking into account the purposes of the processing, to request the completion of incomplete personal data — including by means of a supplementary statement.
If a data subject wishes to exercise this right of rectification, they can contact us at any time.
d) Right to delete (right to be forgotten)
Every person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to require us to delete personal data concerning them immediately, provided that one of the following reasons applies and insofar as processing is not necessary:
- The personal data was collected or otherwise processed for purposes for which they are no longer necessary.
- The data subject withdraws the consent on which the processing was based in accordance with Article 6 (1) (a) GDPR or Article 9 (2) (a) GDPR and there is no other legal basis for processing.
- The data subject objects to processing in accordance with Article 21 (1) of the GDPR and there are no overriding legitimate reasons for the processing, or the data subject objects to the processing in accordance with Article 21 (2) of the GDPR.
- The personal data was processed unlawfully.
- The deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which we are subject.
- The personal data was collected in relation to information society services offered in accordance with Article 8 (1) GDPR.
If one of the above reasons applies and a data subject wishes to have personal data stored by us deleted, they can contact us at any time. We will ensure that the deletion request is complied with immediately.
If the personal data has been made public by us and we, as the person responsible, are obliged to delete the personal data in accordance with Article 17 (1) GDPR, we will take appropriate measures, including technical measures, to inform other data controllers who process the published personal data that the data subject has deleted the published personal data from these other data controllers has requested any links to this personal data or copies or replications of this personal data, insofar as processing is not necessary. We will take the necessary steps in individual cases.
e) Right to restrict processing
Every person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to demand that we restrict processing if one of the following conditions is met:
- The accuracy of the personal data is disputed by the data subject, for a period of time that enables us to verify the accuracy of the personal data.
- The processing is unlawful, the data subject refuses to delete the personal data and instead demands that the use of the personal data be restricted.
- We no longer need the personal data for processing purposes, but the data subject needs them to assert, exercise or defend legal claims.
- The data subject has objected to processing in accordance with Article 21 (1) of the GDPR and it is not yet clear whether our legitimate reasons outweigh those of the data subject.
If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by us, they can contact us at any time. We will arrange for processing to be restricted.
f) Right to data portability
Every person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to receive personal data concerning them, which have been provided to us by the data subject, in a structured, commonly used and machine-readable format. It also has the right to transfer this data to another person responsible without hindrance from the person responsible to whom the personal data has been provided, provided that the processing is based on consent in accordance with Article 6 (1) letter a GDPR or Article 9 (2) letter a GDPR or on a contract in accordance with Article 6 (1) (b) GDPR and the processing is carried out using automated procedures, provided that the processing is not necessary for the performance of a task that is in the public interest or in The exercise of public authority is carried out, which has been delegated to the person responsible.
Furthermore, when exercising their right to data portability in accordance with Article 20 (1) of the GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another controller, insofar as this is technically feasible and provided that this does not affect the rights and freedoms of other persons.
To assert the right to data portability, the data subject may contact us at any time.
g) Right to object
Every person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to object at any time, for reasons arising from their particular situation, to the processing of personal data concerning them carried out on the basis of Article 6 (1) (e) or (f) GDPR. This also applies to profiling based on these provisions.
In the event of an objection, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for processing which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.
If we process personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for the purpose of such marketing. This also applies to profiling, insofar as it is associated with such direct advertising. If the data subject objects to us processing for direct marketing purposes, we will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her that is carried out by us for scientific or historical research purposes or for statistical purposes in accordance with Article 89 (1) of the GDPR, unless such processing is necessary to perform a task carried out for reasons of public interest.
To exercise the right to object, the data subject may contact us directly. Notwithstanding Directive 2002/58/EC, the data subject is also free to exercise his right of objection in connection with the use of information society services by means of automated procedures using technical specifications.
h) Right to withdraw consent under data protection law
Every person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to withdraw consent to the processing of personal data at any time.
If the data subject wishes to exercise their right to withdraw consent, they can contact us at any time.
7. Payment method: Privacy policy for PayPal as a payment method
We have integrated PayPal components on this website. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. PayPal also offers the option of processing virtual payments via credit cards if a user does not have a PayPal account. A PayPal account is managed via an email address, which is why there is no classic account number. PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also performs trustee functions and offers buyer protection services.
The European operating company of PayPal is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg.
If, by clicking on the corresponding button, the data subject chooses to donate money to us using the payment option “PayPal”, the data subject's data will be automatically transmitted to PayPal. By selecting this payment option, the data subject consents to the transfer of personal data required for payment processing.
The personal data transmitted to PayPal is usually first name, last name, address, email address, IP address, telephone number, mobile phone number or other data that is necessary for payment processing. Personal data related to the donation is also necessary to process the purchase contract.
The purpose of transmitting the data is to process payments and prevent fraud. We will transfer personal data to PayPal in particular if there is a legitimate interest in the transfer. The personal data exchanged between PayPal and us may be transmitted by PayPal to credit agencies. The purpose of this transfer is to verify identity and credit.
PayPal may share the personal data with affiliated companies and service providers or subcontractors, insofar as this is necessary to fulfill the contractual obligations or if the data is to be processed on behalf of the company.
The data subject has the option of withdrawing consent to PayPal's handling of personal data at any time. A revocation does not affect personal data, which must necessarily be processed, used or transmitted for (contractual) payment processing.
PayPal's applicable privacy policy can be found at https://www.paypal.com/de/webapps/mpp/ua/privacy-full be retrieved.
8. Legal basis of processing
Art. 6 I lit. a GDPR serves as a legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary to fulfill a contract to which the data subject is a party, as is the case, for example, in processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If we are subject to a legal obligation which requires the processing of personal data, such as to fulfill tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data could be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our office and then their name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Processing would then be based on Art. 6 I lit. d GDPR.
Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the above legal bases are based on this legal basis if processing is necessary to protect a legitimate interest on our part or a third party, provided that the interests, fundamental rights and fundamental freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, he took the view that a legitimate interest could be assumed if the data subject is one of our customers (recital 47 sentence 2 GDPR).
9. Legitimate interests in processing pursued by us or a third party
If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is to carry out our business activities for the benefit of all our employees.
10. Duration for which personal data is stored
The criterion for the duration of storage of personal data is the respective legal retention period. At the end of the period, the corresponding data will be routinely deleted, provided that it is no longer required to fulfill or initiate a contract.
11. Statutory or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide
We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information about the contractual partner).
In order to conclude a contract, it may be necessary for a data subject to provide us with personal data, which must then be processed by us. For example, the data subject is obliged to provide us with personal data when we conclude a contract with them. Failure to provide personal data would mean that the contract could not be concluded.
Before personal data is provided by the data subject, the data subject must contact us. On a case-by-case basis, we will explain to the data subject whether the provision of personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what consequences the failure to provide the personal data would have.
12. Existence of automated decision-making
As a responsible company, we refrain from automatic decision-making or profiling.
13. Integration of third-party services and content
On the basis of our legitimate interests (i.e. interest in analyzing, optimizing and operating our online offering within the meaning of Article 6 (1) (f) GDPR), we use content or service offerings from third parties to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always requires that the third-party providers of this content are aware of the users' IP addresses, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore required to display this content. We make every effort to use only content whose respective providers only use the IP address to deliver the content. Third parties can also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on users' devices and include technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
a) YouTube
We integrate the videos from the “YouTube” platform from the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy statement: https://www.google.com/policies/privacy/ , Opt-out: https://adssettings.google.com/authenticated
b) Google Fonts
We integrate fonts (“Google Fonts”) from the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. According to Google, user data is used solely for the purpose of displaying the fonts in the user's browser. The integration is based on our legitimate interests in the technically secure, maintenance-free and efficient use of fonts, their uniform presentation and consideration of possible licensing restrictions for their integration. Privacy statement: https://www.google.com/policies/privacy/
c) Webflow
We host our website with Webflow. The provider is Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA (hereinafter: Webflow). When you visit our website, Webflow collects various log files, including your IP addresses.
Webflow is a tool for building and hosting websites. Webflow stores cookies or other recognition technologies that are necessary to display the page, to provide certain website functions and to ensure security (necessary cookies).
For details, see Webflow's privacy policy: EU & Swiss Privacy Policy | Webflow 152.
Webflow is used on the basis of Art. 6 para. 1 lit. f DSGVO. We have a legitimate interest in presenting our website as reliably as possible. If a corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be withdrawn at any time.
Data transmission to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: EU & Swiss Privacy Policy | Webflow 152.
Order processing: We have concluded an order processing contract (AVV) with the above-mentioned provider (Webflow). This is a contract required by data protection law, which ensures that it only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.