This policy is intended to give complete and understandable information to those who use the ICBS website https://icbs.it, to those who ask to be registered and to receive newsletters and promotional communications by email, and to those who request information in order to evaluate or actually enter into contracts for ICBS services, in accordance with EU General Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data (General Data Protection Regulation, GDPR) and with the Data Protection Act.
We provide this information on the processing of your personal data not only to meet our legal obligations, but also because transparency and fairness are a fundamental part of our business.
You are therefore informed that your personal data will be processed in accordance with the legal provisions referred to above and with the confidentiality obligations they set out, following the principles of fairness, lawfulness, transparency and protection of your privacy.
Identity of the Data Controller
The controller of the processing of your personal data is REAL TECH SRL - via A. Manzoni 15, 24030, Mapello (BG), Italia, which is responsible for the lawful and correct use of your personal data and which you can contact for any information or request at the following addresses:
- Tel: +39 035 066 7050
- Email: privacy@icbs.it
Purposes and legal basis of the processing
We may process your personal data for the following purposes:
Marketing and newsletter
To send you promotional information about our services, marketing information, remarketing, advertising and other information. The processing of your data is based on your consent, given by registering on the site, by manual registration and by subscribing to the newsletter. You can withdraw your consent at any time by sending us a communication stating your wish to withdraw it, or directly through the unsubscribe links provided in every newsletter and communication sent to you. Withdrawing consent does not affect the lawfulness of any processing carried out beforehand.
Pre-contractual and contractual actions
- To follow up the pre-sales and commercial information activities you have requested;
- To manage, conclude and perform the agreed contractual relationship, including any tax and accounting obligations;
- To manage and act on your contact requests, requests for the supply of services and requests for support in relation to our services.
The processing of your data is justified by pre-contractual activity and, where applicable, by the performance of a contract, when you request information in order to evaluate or actually enter into a contract to receive our services. In that case, the information we ask you for may be necessary to allow those pre-contractual actions to be carried out, or for the service contract to be concluded where that is specified.
Website performance and security
- To collect and handle data arising from the transmission that is inherent in the use of internet communication protocols, through processing that allows users to be identified, the IP addresses or domain names of the computers used by users connecting to the site, including the time of the request, the method used to send the request to the server and the size of the file obtained in response. This data is collected solely in aggregate form to check that the site is working correctly and for security reasons, and is used solely to obtain anonymous statistical information on the use of the site or for technical reasons of correct operation;
- To establish liability in the event of hypothetical computer offences against the IT infrastructure (legitimate interests of the controller).
The processing of your data is justified by our legitimate interest in keeping our infrastructure secure and by our duty to cooperate with the competent authorities should an offence be committed.
Disclosure of data to third parties and abroad, security measures
We may disclose your personal data to advisers in order to meet tax and administrative obligations, and to providers of data processing services and IT services.
Such third parties will always be entities within the EEA, and under no circumstances will your personal data be sent abroad to destinations that are not adequate.
We apply appropriate, state-of-the-art administrative and technical security measures in order to keep your data secure, confidential, intact and available.
Data retention
In general, we keep your personal data for short periods, or for as long as is necessary to perform the contract entered into.
- We may keep some of your personal data to the extent necessary to meet our legal and tax obligations, as well as to protect our contractual interests.
- Exceptionally, we may keep some of your personal data in order to carry out investigative activities, as required by law or by a competent Authority.
- We declare that, three years after the end of the mandatory pre-sales and commercial activities, we will delete personal data that is not otherwise necessary, except where it must be kept in order to defend a case before any competent Court.
Your rights
You have the right to obtain confirmation of whether or not we hold data concerning you, to be told its origin and the purposes and methods of the processing, to ask for the data to be updated, corrected or completed, to object to the processing and to ask for the data to be erased, where the law allows. You also have the right to request copies of the personal information you have provided to us in a structured, commonly used, machine-readable format, and/or to ask us to transmit that information to another service provider (where technically feasible and where the law allows). You can exercise any of the rights described in this section by writing to: REAL TECH SRL via A. Manzoni 15, 24030, Mapello (BG), Italia, or by sending an email to privacy@icbs.it. Please note that we may ask you to verify your identity before taking further action on your request. You may also seek assistance from a competent Supervisory Authority.
