PRIVACY POLICY NEWS LETTER

concerning the sending of the Mapo Tapo S.r.l. Newsletter for promotional purposes of the products and services offered.

The newsletter of Mapo Tapo S.r.l. (hereinafter, "Mapo Tapo") is published on the website www.mapotapo.com and distributed by e-mail - automatically and free of charge - to those who request to receive it by filling in the form on the page of the website.

Mapo Tapo with registered office in viale Piceno, 6, 20129 Milan (MI), acts as the Data Controller of the personal data of the customer/user and of any co-obligors (jointly defined as the "Data Subject") and can be contacted at the e-mail address privacy@mapotapo.com

The data requested and collected through the newsletter subscription form (first name, last name, e-mail contact) with the purpose of promoting the products and services offered by Mapo Tapo are processed not only for sending the newsletter in the terms mentioned above but also for carrying out market research aimed at making promotional activities more focused on the needs, habits and interests of the Interested Parties. When subscribing to the form dedicated to the request for sending the newsletter, emails with profiling purposes enter into automation. Regarding navigation data, they detect those tracked by Freshworks, a provider used for newsletters (Privacy policy of Freshworks: https://www.freshworks.com/privacy)

Purposes of processing

1. performance, subject to your express written consent, of direct marketing activities, such as the sending by e-mail of advertising material and communications having informative and/or promotional content in relation to products or services provided and/or promoted by the Data Controller, including through the sending of the newsletter.
2. carrying out, subject to your express written consent, individual or aggregate profiling and market research activities aimed, for example, at analyzing consumption habits and choices, processing statistics on the same or assessing the degree of satisfaction with respect to the products and services offered.

Legal basis of the processing

The legal basis of the processing is to be found in the free and informed consent provided by the Data Subject downstream of the completion of the dedicated form for the request for activation of the newsletter service in epigraph and/or in the free and informed consent by the Interested Party for the profiling activity referred to above, pursuant to and for the purposes of art. 6, §1, lett. a) of Reg. UE/679/2016.

The consent given by the Data Subject is revocable at any time by submitting a written request to the dedicated email address (privacy@mapotapo.com): if the Data Subject withdraws his/her consent to the service, he/she will no longer be able to receive commercial communications also through the sending of the newsletter or may no longer be subject to profiling.

Nature of provision of data

For the purposes referred to in letters a) and b) of the paragraph "Purposes of the processing", the provision of data is optional, and any refusal to provide such data and to give the relevant consent to the processing to the collection of which the Data Controller is obliged to entails

the impossibility for the Data Controller to follow up on the direct marketing and profiling activities indicated therein.

Treatment modalities

Processing: any operation or set of operations, performed with or without the aid of

automated processes and applied to personal data or sets of personal data, such as collecting,

recording, storage, consultation, communication by transmission.

The data may be processed by manual or computerized means, suitable to ensure their security, confidentiality and avoid unauthorized access.

Scope of data dissemination

The data processing will be carried out by personnel directly employed by the Data Controller and/or by natural or legal persons specifically identified by the latter as Data Processors or Authorized Data Processors. The Data Subject may request a list of any appointed Data Processors. The Data provided will in no case be subject to dissemination or communication to third parties, with the exception of subjects whose right to access the data is recognized by provisions of law or orders of the authorities as well as subjects, including external and/or foreign, which the Data Controller uses for the performance of activities instrumental and/or ancillary to the provision of services, including providers of software solutions, web applications and services of

storage provided also through Cloud Computing systems.

Data may be freely transferred outside the national territory to countries located in the European Union, but may also be transferred outside the European Union.

In the case of non-EU transfer, standard contractual clauses contained in Decision 2021/914/EU and the orders of the Data Protection Authority will be signed, as well as in accordance with Articles 45 and 46 of EU Regulation 679/2016.

Data Retention

The processed data will be retained until the purposes for which they were collected are achieved, as well as having regard to the legitimate interest of the Data Controller and for fulfilments ex lege and up to 24 months after the consent given by the Data Subject to receive the newsletter for promotional purposes, unless the consent is revoked, for 12 months in case of consent to profiling activities, unless the consent is revoked.

You may contact the Data Controller to exercise your rights as provided for in EU Regulation 679/2016 and therefore: request access to personal data, rectification or erasure of personal data, restriction of processing, opposition to processing. You may also exercise the right to data portability or again the right not to be subjected to a decision based solely on automated processing.

Requests for the exercise of the above rights and any other request regarding this policy may be forwarded to the Data Controller at the following address: privacy@mapotapo.com

The right to complain, on the other hand, may be freely exercised by the Data Subject by preparing a document to be sent to the Authority by certified e-mail message to the address "protocollo@pec.gpdp.it".

The information referred to herein and any communications and actions taken pursuant to Articles 15,16,17,18,20,21 and 22 of EU Regulation 679/2016 are free of charge. If the data subject's requests are manifestly unfounded or excessive, in particular due to their repetitive nature, the Data Controller may:

(a) charge a reasonable fee taking into account the administrative costs incurred in providing the information or communication or taking the requested action; or

(b) refuse to comply with the request. The burden is on the Data Controller to prove that the request is manifestly unfounded or excessive.

For anything not mentioned therein, express reference is made to the relevant provisions in force, with particular reference to EU Regulation 679/2016.

Last update

27.02.2024