Privacy and Cookies
(Last revised: 07/02/2019)
We therefore invite you to carefully read the following, before providing any personal data. By using the Phoenix Electronic System s.r.l. Websites and Products, you authorize the processing of your personal data by Phoenix Electronic System s.r.l., in accordance with the provisions of this Policy. If you do not agree with the terms of this Policy, please DO NOT use Phoenix Electronic System s.r.l. Websites and Products.
For any questions regarding this Policy, please contact us at: firstname.lastname@example.org, writing “Privacy” in the subject.
1. Collection of personal information
To provide a better service and have a deeper knowledge of the needs and interests of its Users, Phoenix Electronic System s.r.l. collects, exports and uses personal data after submitting appropriate information and having obtained an explicit consent.
For example, when you place orders for products or services, request information, subscribe to support and marketing materials, register yourself or register Phoenix Electronic System s.r.l., you must provide personal information to complete the registration process. The personal data that, in these cases, may be requested concern: contact information (e.g., name, address, telephone number and e-mail address), information such as personal codes and passwords, data to allow billing and various transactions, preferences regarding products and services.
If the User posts, comments or shares personal information, including photographs on any forum, social network, blog or other similar forum managed by Phoenix Electronic System s.r.l., he must be aware that such personal information may be read, viewed, collected or used by other Users participating in such forums and may be used to contact him, send him unsolicited messages or for purposes upon which neither the User nor Phoenix Electronic System s.r.l. have control. Phoenix Electronic System s.r.l. is not responsible for the personal information that the User decides to send to these forums.
During registration, personal data may be requested, such as name, e-mail address, address, and choice of password. Phoenix Electronic System s.r.l. will send a welcome e-mail to each visitor and/or customer, requesting to verify the e-mail address he has provided.
It is very important to enter a valid e-mail, as it will be used to sent purchase confirmations, download links, activation keys, product and support information. If an e-mail address is not valid, the associated password may be deactivated by Phoenix Electronic System s.r.l.
When the User purchases a product on Phoenix Electronic System s.r.l. Websites, he is requested to provide your contact, billing, and shipping information. This data will be used to process the order, to make the payment, and to send the ordered products. If any problems occur during the purchase process, a Phoenix Electronic System s.r.l. representative will contact the User by e-mail, telephone, fax or mail in order to resolve them.
When the User downloads a demo version, a free software or files in general, he may be requested to provide personal data such as his e-mail address. In this case, this e-mail address will be used to send messages related to the procedure, such as download links, activation keys, support information and upgrades for the selected software.
1.4 Data contained in websites, e-mails and apps
In addition to the information provided, Phoenix Electronic System s.r.l. may also collect some User’s data during his consultation of a Phoenix Electronic System s.r.l. Website, through commonly used automated tools such as, for example, cookies, Web beacons and embedded links. These tools collect some standard traffic information that the browser sends to Phoenix Electronic System s.r.l. Websites, such as, for example, browser type and language, access times and data about the website address used for the contact.
Information on the IP address (Internet Protocol), on the clickstream behavior (i.e. consulted pages, open links and other actions taken by the User in connection with Phoenix Electronic System s.r.l. Websites) and product information may also be collected.
Finally, Phoenix Electronic System s.r.l. can use some of the automatic data collection tools listed above, also to analyze its own applications and emails that it forwards: in this way, for example, it can collect information on the use of applications, on the opening of messages or on clicks on the links contained in these messages.
2. How the collected data are used
The data collected by Phoenix Electronic System s.r.l. are processed without the User’s express consent (Article 24 paragraph a), b), c) of the Privacy Code and art. 6 paragraph b), e) of the GDPR), for various purposes including, for example:
a. Assisting the User in completing a transaction or an order;
b. Fulfilling the pre-contractual, contractual and fiscal obligations arising from existing relationships with the User;
c. Providing technical support and customer care service.
The data collected by Phoenix Electronic System s.r.l. are used after a specific and express consent (articles 23 and 130 of the Privacy Code and article 7 of the GDPR), for various purposes including, for example:
a. Submitting products and services to the User;
b. Providing personalized promotional offers;
c. Requesting opinions or feedback from the client and giving him the opportunity to try out software;
d. Searching and implementing product updates;
e. Allowing the User to recommend a friend (Refer-a-Friend) who may be interested in our offers, as permitted by law;
f. Selecting the contents to be submitted to the User;
g. Measure the performance of marketing, advertising and Phoenix Electronic System s.r.l. Websites.
h. Performing Remarketing and Behavioral Targeting activities.
IThe provision of data for the purposes referred to in point 1) is mandatory. In their absence, Phoenix Electronic System s.r.l. will not be able to guarantee its services.
The provision of data for the purposes referred to in paragraph 2) is optional. The User can therefore decide not to provide any data, or to subsequently deny the possibility of processing data already provided: in this case, he will not receive newsletters, commercial communications and advertising material concerning the Services offered by Phoenix Electronic System s.r.l.. However, he will continue to be entitled to receive the Services referred to in point 1).
Specifically, Phoenix Electronic System s.r.l. may use the personal data collected to periodically contact the User, in order to send important information about its Products, Services and/or Websites. Only upon specific request by the User, Phoenix Electronic System s.r.l. can also send newsletters information, with special offers and/or other opportunities offered by partner companies that may interest him.
The User may choose the type of communications he wants to receive from Phoenix Electronic System s.r.l. and revoke his consent at any time, through his own Online User Profile or by contacting Phoenix Electronic System s.r.l. directly.
Furthermore, if the User no longer wishes to receive these communications, he may revoke his registration (Article 130 paragraph 4 of the Privacy Code) by clicking on the appropriate link contained in the e-mail message sent to him. After the cancellation request, the e-mail address of the User will be removed from Phoenix Electronic System s.r.l. mailing list as soon as possible, normally before the next mailing. No further commercial communications will be sent: however, service communications may be sent, for example relating to the ongoing transactions.
3. Processing methods
The processing of personal data is carried out by means of the operations mentioned in Art. 4 of the Privacy Code and Art. 4 no. 2 of the GDPR and, more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.
The User’s personal data are subject to both computer and paper processing, and/or to automated processing.
Phoenix Electronic System s.r.l. will process personal data for the time necessary to fulfill the aforementioned purposes and, in any case, for no more than 10 years after the closing of the position (for Service Purposes) and no later than 2 years from the collection of data (for Marketing Purposes).
4. Disclosure of the information collected
Without the need for an express consent, in compliance with Art. 24 paragraphs a), b) and d) of the Privacy Code and Art. 6 par. b) and c) of the GDPR, the User’s data may be made accessible, for the purposes referred to in paragraph 2:
– to Phoenix Electronic System s.r.l employees and collaborators in Italy and abroad, in their capacity as agents, internal processing managers and/or system administrators;
– to third-party companies or other subjects (for example, credit institutions, professional firms, consultants, etc.) who carry out outsourcing activities on behalf of Phoenix Electronic System s.r.l, in their capacity as external data controllers.
Phoenix Electronic System s.r.l. can not sell, rent, transfer or provide the personal data of its Users to third parties, except in the cases referred to in this Policy or only to comply with legal obligations.
Phoenix Electronic System s.r.l. may share some information with its partners for marketing or promotional purposes: in these cases, the data will always be provided in aggregate form, so as not to allow any connection to identifiable personal data.
The User’s profile and contributions, present on Phoenix Electronic System s.r.l website, will be published and identifiable through the User’s name, expressed in one of the forms indicated as chosen by the User. In any case, Phoenix Electronic System s.r.l. will not communicate the e-mail address or other data of a registered User to other Users of the Site, nor will it publicly disclose them without a prior User’s authorization.
5. Links to other websites
6. Access, update or correction of Customer Data
The User can review and update the personal data provided during registration, by accessing directly to his Online User Profile if present; in any case, to modify, correct, anonymize or delete his data, the User can send an e-mail to Phoenix Electronic System s.r.l. – Customer Service (email@example.com) or send a letter to:
Phoenix Electronic System srl
Via Salaria, KM 92.300 – 02100 Santa Rufina, Rieti – Italy
7. Protection of personal data
To prevent unauthorized access or disclosure and to ensure the protection and proper use of personal data stored in its systems, Phoenix Electronic System s.r.l. takes the necessary physical, technical and administrative measures. For example, the access to personal data is restricted to employees who reasonably need to access them and use processes such as password hashing to protect data from unauthorized access.
All transactions carried out on Websites by means of a Credit Card are protected by encryption: Phoenix Electronic System s.r.l. uses the Secure Socket Layer (SSL) protocol. No Credit Card number is recorded, and even during the transaction the essential data (credit card numbers, validation number, etc.) are entirely handled by PayPal or other payment services.
Phoenix Electronic System s.r.l. uses some sub-agents, suppliers and content distribution networks (ex: Service Data Storage, Mail Marketing, Payment Gateway, etc.) for the support in the provision of its services. Phoenix Electronic System s.r.l. requires its sub-agents to meet obligations equivalent to those required by Phoenix Electronic System s.r.l. and in compliance with the GDPR.
Despite the adoption of technical and organizational measures to protect the User’s personal data from unauthorized or unlawful processing, as well as from their loss, destruction or damage, Phoenix Electronic System s.r.l. cannot absolutely guarantee the security of this information.
8. Children’s privacy
Phoenix Electronic System s.r.l. does not knowingly collect information about children under 13 and its Websites are aimed at a general public. In the event that a minor, known by Phoenix Electronic System s.r.l. to be under the age of 13, sends personal information, the data collected will only be used to replay directly to that child and inform him of the need to obtain the consent of his/her parents/guardians. Phoenix Electronic System s.r.l. encourages parents and guardians to play an active role in their children’s online activities and interests.
9. The User’s Privacy rights
In his capacity as an interested party, the User enjoys the rights referred to in Art. 7 of the Privacy Code and in Art. 15 of the GDPR, and particularly the rights of:
a) Requesting information on the processed Personal Data concerning him;
b) Rectifying, updating or integrating the inaccurate or incomplete Personal Data concerning him;
c) Canceling or requesting the cancellation of personal data concerning him;
d) Limiting, under certain circumstances, the way in which Phoenix Electronic System s.r.l. processes the Personal Data concerning him;
e) Revoking any consent that the User has granted to Phoenix Electronic System s.r.l. about the processing of the Personal Data concerning him;
f) Opposing the processing of personal data concerning him, on the basis of legitimate interests of third parties;
g) Obtaining the portability of Personal Data concerning him and that Phoenix Electronic System s.r.l. processes through automated tools, on the basis of his consent or a contract that he has concluded with Phoenix Electronic System s.r.l.;
h) Submitting to a Supervisory Authority, within the European Economic Area, a complaint for invasion of privacy if the User is not satisfied with the way in which Phoenix Electronic System s.r.l. has processed his Personal Data or any request concerning the User’s privacy.
Phoenix Electronic System s.r.l. also reserves, at any time and without notice, the right to delete, modify or update the Website and its Contents. Phoenix Electronic System s.r.l. reserves the right, at any time, with immediate effect, without prior notice, in its sole discretion and for any reason, to restrict, refuse or interrupt, in whole or in part, the access to its Website by any User.
12. Owner, manager and agents
The owner and responsible for data processing is:
Phoenix Electronic System srl
Via Salaria, KM 92.300 – 02100 Santa Rufina, Rieti, Italy
The updated list of the Personal Data Processor and the designated data processing staff is kept at the registered office of the Data Controller.
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