Privacy Policy
Emotion Network Srl, with registered office located at via Morigi n. 3/A, 20123, Milan (MI), Tax ID, VAT number and registration number in the Company Register at the Milan Chamber of Commerce no. 11180210962, no. REA MI2585200 (hereinafter, the “Data Controller” or “DC”), owner of the website https://www.techemotion.com (hereinafter, the “Website"), through which it provides the service called ........... (hereinafter "Service"), as Data Controller of personal data of the Users of both the Website and the Service (hereinafter, the "Users") hereby provides the Privacy Policy pursuant to Art. 13 of EU Regulation 2016/679 of 27 April 2016, as transposed into Italian law (hereinafter, the “Regulation” or “Applicable Law” or “GDPR”).
The DC is not responsible for the regulatory compliance of other websites that may be accessible by navigating the Website.
Navigation and use of this Website, the Service as well as any other services offered through the Website are reserved to individuals who have reached eighteen years of age. Thus, the DC does not collect personal data relating to persons under the age of 18. The DC will promptly delete all personal data involuntarily collected and relating to persons under the age of 18.
The DC guarantees strict adherence to privacy and protection of Users’ personal data laws. For more information about this privacy policy, Users can contact the DC at any time:
- by sending a registered letter with return receipt to the Data Controller’s registered office (via Morigi n. 3/A, 20123, Milan (MI);
- by sending an email to the following address: [email protected]
The DC has not appointed a Data Protection Officer (“DPO”), as the DC is not subject to the designation obligation set forth in Art. 37 of the Regulation.
1. Purpose of the Treatment
Users’ personal data will be lawfully processed by the DC pursuant to Art. 6 of the Regulation for the following purposes:
- Contractual obligations and provision of the Service: Personal data are collected and processed to either allow navigation on the Website or the implementation of the General Conditions that regulate the provision of the Service and the fulfillment of specific requests by the User (including subscriptions to use the contents of the platform). The user data collected by the DC for the purpose of using the Service include: name and surname, e-mail address, payment details, as well as any other personal information voluntarily communicated by the User to the DC. Unless the User gives his free and optional consent to the processing purpose described in paragraph 2 below, the User’s personal data will be used by the DC for the exclusive purpose of ascertaining the User’s identity (including through validation of the e-mail address), thus avoiding potential scams or abuses, and to contact the User solely for Service reasons (e.g. sending communications relating to the Service). Without prejudice to other provisions of this Privacy Policy, in no case will the DC render Users’ personal data accessible to other Users and/or third parties.
- Administrative-accounting purposes: Personal data are collected and processed to perform activities having organizational, administrative, financial and accounting nature, such as internal organizational activities and other activities required for the fulfillment of contractual and pre-contractual obligations;
- Legal obligations: Personal data are collected and processed to fulfill the obligations established by Italian law, by an authority, by a regulation or by European Union law.
The provision of personal data for the processing purposes indicated above is optional but necessary since refusal to provide them will prevent Users from using the Service.
2. Additional processing purposes: Marketing (sending of advertising materials, direct sales and commercial communications, newsletter) and Profiling
With the free and optional consent of the User, some personal data of the User (such as name, surname, e-mail address) may be processed by the DC for profiling or marketing purposes as well (sending of advertising materials, direct sales, commercial communications, sending of newsletters containing information on news relevant to the sector relating to the activities of the DC), or so that the DC can contact the User by e-mail for the sale of products and/or services offered by the DC itself and/or by third-party companies, communicate offers, promotions and commercial opportunities, as well as to inform Users about subscription opportunities to some services.
In the event the User refuses to consent to the type of data collection and processing described in this paragraph, the possibility of using the Service will not be affected in any way. If the User gives consent, such consent may be revoked at any time, through a specific request to the DC pursuant to paragraph 5 below. The User may also easily withdraw his consent to receive further promotional communications via e-mail by clicking on the “Unsubscribe” link, contained in all e-mails.
The DC informs that, following the exercise of the User’s right to object to the sending of promotional communications via e-mail, it is possible that, for technical and operational reasons (e.g. creation of contact lists completed shortly before receipt by DC of the consent withdrawal request by the User) the User may continue to receive promotional messages. If the User keeps receiving promotional e-mails after 24 hours following the exercise of his right to consent withdrawal, please report the problem to the DC, using the contact methods indicated in paragraph 5 below.
3. Processing Methods and Data Storage Times
The DC will process Users’ personal data using manual and IT tools, with methods strictly related to the relevant purposes and, in any case, in order to guarantee the security and confidentiality of data.
Website Users’ personal data will be stored for the time strictly necessary to carry out the primary purposes illustrated in paragraph 1 above, or in any case for the time period strictly necessary to the protection of both the Users’ and the DC’s interests.
With regard to the purposes described in paragraph 2 above, Users’ personal data will be stored, in any case, for no more than 24 (twenty-four) months.
4. Scope of Communication and Dissemination of Data
The employees and/or collaborators of the DC in charge of managing the Website, the Service and Users’ requests may have access to Users’ personal data. These subjects, who have been specifically instructed by the DC pursuant to Art. 29 of the Regulation, will process the User’s data exclusively for the purposes indicated in this Policy and in full compliance with the provisions of the Applicable Regulations.
Users’ personal data may also be disclosed to third parties who may process them on behalf of the DC as “Data Processors”, such as, by way of example, IT and logistics service providers necessary to the operation of the Website, outsourcing or cloud computing service providers, other professionals and consultants.
Users have the right to obtain a list of all Data Processors appointed by the DC, by submitting a request to the DC in the manner described in paragraph 5 below.
5. Users’ Rights
Users can exercise the rights referred to in Artt. 15-22 of the Regulation, by contacting the DC in the following ways:
- by sending a registered letter with return receipt to the DC’s registered office (via Morigi n. 3/A, 20123, Milan (MI));
- by sending an email to the following address: [email protected]
Pursuant to the Applicable Regulations, the DC informs that Users have the right to learn (i) the source of their personal data; (ii) the purposes and methods of processing; (iii) the logic applied in case of data processing performed with the aid of electronic instruments; (iv) the identification information of the DC and Data Processors; (v) information on the subjects or categories of subjects whom Users’ personal data may be communicated to or who can gain access to them as Processors.
Furthermore, Users have the right to obtain:
a) the access, update, rectification or, when interested, integration of data;
b) the cancellation, anonymous transformation or prevention of unlawfully processed data, including data whose storage is unnecessary for the purposes they were collected or subsequently processed for;
c) the attestation that the operations referred to in letters a) and b) above have been brought to the attention, including with regard to their content, of those whom the data have been communicated or disseminated to, except in cases where this attestation is impossible or requires the use of means manifestly disproportionate to the protected right.
In addition, Users have:
a) the right to withdraw their consent at any time, if the treatment is based upon their consent;
b) (if applicable) the right to data portability (right to receive all their personal data in a structured format, commonly used and readable by an automatic device), the right to limit the treatment of their personal data and the right to cancellation (“right to be forgotten”);
c) the right to object :
i) in whole or in part, for legitimate reasons, to the processing of their personal data, even if pertinent to the purpose of the collection;
ii) in whole or in part, to the processing of their personal data for the purpose of sending advertising materials or direct sales or for performing market research or commercial communications;
iii) at any time, to the processing of their personal data performed for direct marketing purposes including profiling insofar as it is connected to such direct marketing.
d) if they believe that the processing of their personal data violates the Regulation, Users have the right to file a complaint with a Supervisory Authority (either in the Member State where they usually reside, or in the one where they work or in the one where the alleged violation has occurred). The Italian Supervisory Authority is the Italian Data Protection Authority, headquartered in Piazza Venezia, n. 11, 00186 - Rome (RM) (http://www.garanteprivacy.it/ ).
The DC is not responsible for updating all the links that can be viewed in this Policy; therefore, whenever a link is not working and/or updated, Users acknowledge and accept that they shall always refer to the document and/or section of the websites referred to by that link.
Last updated: May 2023
