1. DATA CONTROLLER
The LargeTrader.com site (hereinafter "Site") is owned and managed by Ideas Incubator AG (for company data see point 9), as the Data Controller of the information collected from users (hereinafter "user" , "users" or "you").
The data controller of user data is Ideas Incubator AG, in the person of its pro tempore legal representative, with registered office in Buochs (CH), Strasse Vorderlinden, 2, email firstname.lastname@example.org.
The updated list of data processors and persons in charge of processing is located at the registered office of the data controller.
The Data Controller with specific assessments pursuant to Article 37 of the GDPR has excluded the need to proceed with the appointment of a Data Protection Officer (DPO).
The security measures applicable to this Site have been defined and developed to ensure that the information provided by users is treated in compliance with the principles of lawfulness, correctness, transparency, purpose limitation and retention, data minimization, accuracy, integrity and confidentiality. , in compliance with the national and European regulations in force.
2. PERSONAL DATA OBJECT OF THE TREATMENT
"Personal Data" means any information relating to an identified or identifiable natural person with particular reference to an identifier such as a name, an identification number, location data or an online identifier.
The Personal Data collected by the Site are as follows:
A) Navigation data
The computer systems and software procedures used for the correct functioning of the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the navigation of the websites. This information is not collected to be associated with identified interested parties; however, by their very nature they could, through processing and association with data held by third parties, allow users to be identified. These include the IP addresses or the names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server and other parameters relating to the operating system and the IT platform used by the user.
The above data is used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site.
B) Data provided voluntarily by the user
Through the Site the user has the possibility to voluntarily provide Personal Data, such as name and e-mail address, and telephone to contact Ideas Incubato AG or leave a comment through the forms of the Site.
Ideas Incubator AG may also ask the user to provide certain information in the event of problems with services on the Site.
The personal data provided in this way are used for the sole purpose of satisfying or responding to the requests transmitted and are communicated to third parties only if this is necessary for this purpose.
In this sense, the user grants the widest indemnity on this point with respect to any dispute, claim, request for compensation for damage from processing, and so on that should reach Ideas Incubator AG from third parties whose Personal Data have been processed through your use of the Site in violation of applicable law.
3. PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The Personal Data you provide through the Site will be processed by the Data Controller for the following purposes:
a) purposes related to the provision of services available through the Site (eg: contact request through the forms on the Site, e-book download, course download, etc.);
b) purposes of statistical research / analysis on aggregated or anonymous data, therefore without the possibility of identifying the user, aimed at measuring the functioning of the Site and its operational functions, including the resolution of any technical problem;
c) purposes aimed at preventing or preventing fraudulent activities or improper use that could damage the Ideas Incubator AG site, or compromise the security of operations;
d) purposes related to the fulfillment of a legal obligation to which Ideas Incubator AG is subject;
e) purposes necessary to ascertain, exercise or defend a right in court or whenever the judicial authorities exercise their judicial functions.
The legal basis for the processing of Personal Data for the purpose referred to in point a) is the provision of a service or the response to a request, which do not require the consent of the users, pursuant to the applicable legislation.
The purpose referred to in point b) does not involve the processing of Personal Data, while as regards the purposes referred to in points c) and e), the processing is necessary for the pursuit of a legitimate interest of Ideas Incubator AG.
Finally, the purpose referred to in point d) represents a legitimate processing of Personal Data as it is necessary to fulfill a legal obligation to which Ideas Incubator AG is subject.
It should be noted that the treatments carried out on the basis of the consent given by the user also include those for marketing purposes, by which we mean the activities of commercial promotion, surveys and market research, statistical processing.
4. REFUSAL BY THE USER TO PROVIDE THEIR EPRSONAL DATA OR TO CONSENT TO THE TREATMENT
The refusal by the user to provide his personal data has different consequences depending on the case, as specified below.
Refusal to provide the data necessary for the performance of the requested service (Article 13, paragraph 2, letter e of the GDPR)
The provision of Personal Data by the user is optional: the user is free to provide personal data contained in the forms on the Site or indicated in the contacts with the Data Controller, but if the user does not want to provide them this can prevent themselves to use the Site and the services listed in point 2.b of this privacy statement.
Through the Site we do not ask the user for data of a sensitive nature (e.g. relating to detecting racial and ethnic origin, religious, philosophical, political beliefs, etc.) or judicial (data relating to criminal records, or relating to the quality of accused or suspected).
Refusal to consent to the processing of personal data for marketing purposes.
In the event that the user does not consent to the processing of their personal data for marketing purposes, the processing will not take place for these purposes.
The above does NOT affect the provision of the requested services, nor on those for which the user has already given his consent, where required.
In the event that the user has given consent and subsequently revokes it or opposes the processing for marketing purposes, Ideas Incubator AG will suspend the processing for these activities, without this having consequences or harmful effects for the user and for the required performance.
5. METHODS, LOGICS OF TREATMENT AND STORAGE TIMES
The processing of user information is carried out only if strictly necessary, also with the aid of electronic or automated means and is carried out by Ideas Incubator AG and / or by third parties which Ideas Incubator AG can use to store, manage and transmit the data themselves (for more details see point 5).
The processing will be carried out with the logic of organization and processing of Personal Data, also relating to the logs originating from the access and use of the services made available via the web, related to the purposes indicated above and, in any case, in order to guarantee the security and confidentiality of data.
The Personal Data processed will be kept for the maximum storage times provided for by the GDPR and by the applicable legislation and, in any case, for the duration strictly necessary to achieve the purposes indicated in point 2. More details regarding the retention period of the Personal Data and / or the criteria used to determine this period can be requested by writing to the Joint Data Controllers (see point 9 for company details).
Ideas Incubator AG undertakes to protect the security of Personal Data during their sending. Information on purchase operations (eg credit card number) is managed securely, through selected suppliers who guarantee to adopt the most appropriate security measures.
In any case, Ideas Incubator AG advises users to adopt suitable protections against unauthorized access to their passwords and to their computer and to always make sure that they are logged out when using a computer shared with other users.
7. TRANSFER OF PERSONAL DATA OUTSIDE THE COMPANY
Ideas Incubator AG will not sell, disclose or distribute personal data to Third Parties except as specified in this statement.
The user's Personal Data may be shared, for the purposes specified in point 2, with: employees and consultants authorized to manage the Site and provide the related services (e.g. customer service, management of IT systems, etc.), employees and consultants of the finance, administration, accounting and other offices of Ideas Incubator AG, in their capacity as data processors and / or internal data processors.
The Parties to which Ideas Incubator AG may transfer the user's personal data may in some cases be located in a third country to the European Union (non-EU), meaning a country located outside the European Economic Area (in short EEA). , where the GDDPR does not apply territorially. This means that personal data can be transferred to a country that is not subject to the provisions of the latter. In these cases, Ideas Incubator pursuant to Article 25 of the GDPR, in the case of a third country not recognized as "adequate" by the European Commission, has undertaken to adopt adequate measures to ensure that personal data continue to be protected and processed in the compliance with the provisions of the GDPR by entering into "data sharing agreements" signed by both parties.
The user's information may also be communicated to the following subjects or categories of subjects: police forces, armed forces and other public administrations in order to fulfill the obligations established by laws, regulations, protocols and by national or European legislation; agencies or professionals for debt collection (e.g. outstanding debts towards us) or for the defense in court of Ideas Incubator AG, for example in the case of violations by network users.
The aforementioned parties will process the information as independent Data Controllers.
8.DATA OF USERS UNDER AGE
The Site is not aimed at minors under the age of 18 and Ideas Incubator AG does not intentionally collect Personal Data from them. In the event of accidental recording of any information on minors, Ideas Incubator AG will delete them in a timely manner at the request of users.
We inform you that articles 15 and following of the GDPR give users the exercise of specific rights towards the Data Controllers. In particular, the user can:
- obtain confirmation of the existence and access to Personal Data concerning him, even if not yet registered, and ask to know their origin, as well as the purposes, storage times, methods of treatment and the logic applied in case of treatments carried out with automated tools;
- revoke any consent given in relation to the processing of your Personal Data, without prejudice to the lawfulness of the processing carried out up to that moment;
- receive the Personal Data processed in a structured format, commonly used and readable by an automatic device and, except in the case in which it is not technically feasible, transmit your data directly to another Data Controller;
- obtain the cancellation, transformation into anonymous form or blocking of data which need not be kept for the purposes for which the data were collected and processed;
- obtain the updating, rectification and integration of the data processed;
- object, in whole or in part, for legitimate reasons, to the processing of personal data concerning him, even if pertinent to the purpose of the collection;
- propose a complaint to the supervisory authorities.
The exercise of these rights must not prejudice and / or harm the rights and freedoms of others.
The user can exercise these rights at any time by writing by post to the address of Ideas Incubator AG in Buochs (CH), Strasse Vorderlinden, 2, or by e-mail to the e-mail address email@example.com
Resta inteso che, laddove le richieste siano presentate tramite mezzi elettronici, le informazioni saranno fornite gratuitamente e in un formato elettronico di uso comune.
Qualora le richieste dell'utente siano manifestamente infondate o eccessive, in particolare per il loro carattere ripetitivo, Ideas Incubator AG può alternativamente: addebitare un contributo spese ragionevole tenendo conto dei costi amministrativi sostenuti per fornire le informazioni o la comunicazione o intraprendere l'azione richiesta; oppure rifiutare di soddisfare la richiesta. In entrambe le circostanze il Titolare fornisce un'adeguata giustificazione all'utente.
In the event that Ideas Incubator AG makes changes that are considered important, users will be informed through the Site.
Last updated: August 15, 2018