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Introduction
In accordance with article 13 of Legislative Decree 196/2003 as further amended (“Personal Data Protection Code”), Starteed Group S.r.l. (“Starteed”) has prepared this this policy (“Privacy Policy”). The Policy shall apply to everyone (“User” or “Users”) accessing this website (“Site”), technically created, elaborated and managed for the promoter or manager of a crowdfunding or crowdcreation campaign by Starteed and hosted on its proprietary platform, regardless of how such User accesses to services provided through the Site, and if he is has completed the registration to the Site
Therefore it is important, in the interest of every User, that this Privacy Policy and its contents is carefully read and understood before browsing the Site and using the services there provided. In any case, for further clarifications, you may contact us at privacy@starteed.com.
Personal data submitted by every User for the purposes of accessing and using the Site and the services there provided, in addition to further information collected pursuant to article 3 below (“Personal Data”), may be processed according to the regulation in force and in compliance with principles of fairness, lawfulness and transparency, privacy and with the purpose to protect Users’ rights.
This Privacy Policy exclusively concerns the processing of Personal Data relating to the Site and shall not apply to third parties’ websites retrievable by a link on the Site, neither to the activity of third parties’ services suppliers who may have temporary access to Users’ Personal Data.
Every User is free to decide whether to give or not his consent to his Personal Data processing and to their dissemination and communication, although the failure to provide certain Personal Data may prevent the Site from fully delivering its services.
Since the Data Controller, as further defined, reserves the right to modify or amend this Privacy Policy anytime and with no prior notice, it is recommended to frequently check this page for any updates to its content.
Any amendment to this Privacy Policy shall be published on the Site, without prejudice to former versions, that will be kept available on the same for consultation.
This Privacy Policy has been prepared also in the interest of the promoter/manager of the crowdfunding or crowdcreation campaign indicated in the Site, who may be contacted for any further requests and clarifications. He is a separate and autonomous data controller with respect to Personal Data communicated by Starteed for the Type A purposes (use of the Site and related services) as indicated in article 5 of this Privacy Policy and, in particular, to ensure a correct and efficient crowdfunding or crowdcreation campaign management, though the delivery to Users of communications and updates on said campaign, until its expiration.
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Data controller and data processor
The Data Controller is Starteed Group S.r.l., with registered office at Via Bligny 5, Torino (Italy), VAT Number and Business Register no.11170160011, through its legal representative.
Starteed Group S.r.l., through its legal representative, shall be also considered as Data Processor.
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Types of data collected
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Browsing data
IT systems and software procedures that allow the operation of the Site automatically acquire some Personal Data according to the internet protocol
Although such information are not collected to identify any subjects they may, through electronic data processing and elaboration of third parties’ data, achieve the same result
IP addresses, internet domain names of Users’ computer, URI addresses, time of the request, server’s mode of the request, response file’s size, server’s response code and other parameters about Users’ operating system and computing environment may be an example.
These data are used only to acquire statistical information, anonymously, on the Site use and its proper operation and will be erased after being processed.
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Data provided by the Users on a voluntary basis
Among the types of Personal Data collected through the Site, also through third parties, there are: usage data, phone number, email address, first name, last name, profession, address, ZIP/Postal code, city, sex, birth date, and other information specifically required by the payment provider to complete the transaction.
Emailings to addresses indicated on the Site involve the acquisition of the sender’s address and other data in the message.
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Cookies
The Site contains third parties’ cookies to provide further services and applications to the Users and to improve its operation, including social networks’ buttons. This Privacy Policy shall not apply to third parties’ services and the Site has no control upon their cookies, fully managed by third parties.
For further details on the matter, please read carefully the Cookie Policy uploaded on the Site.
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Purposes of data processing
Starteed uses the Personal Data in accordance with the Personal Data Protection Code and only with the consent of every User as provided for by the Italian Privacy Authority, for the following purposes.
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Type A purposes (use of the Site and related services)
Every User, by simply browsing the Site or activating any service there provided, shall confirm to have fully read and accepted this Privacy Policy, and shall agree that his Personal Data may be used for:
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the execution and the management of the Site and related services provided to registered Users, also through third parties’ services;
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the fulfillment of any legal obligation, as well as of any other law or public authority provision.
The User’s refusal to accept any part of this shall prevent him from activating any service and, therefore, he shall abandon the Site navigation.
Furthermore, upon registration, every User shall be free to grant or refuse its consent for type B and type C purposes, as described below.
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Type B purposes (marketing by Starteed)
Any User, by simply checking the first consent box during registration, and therefore granting its express consent, shall also confirm to have fully accepted this Privacy Policy and shall agree that his Personal Data may be used by Starteed for marketing and other promotional activities such as sending advertising materials, direct marketing, marketing research, commercial communication.
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Type C purposes (communication and transfer to third parties)
Any User, by checking the second consent box during registration, and therefore granting its express consent, shall also accept this Privacy Policy and that his Personal Data may be used for communication and/or transfer to third parties, for marketing and other promotional activities, with whom Starteed, from time to time, may enter into a commercial agreements, partnerships, common projects or initiatives.
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Methods and place of the processing
Personal Data are carried out using computers and/or IT enabled tools and only as long as strictly necessary for the purposes for which they have been collected, except for type B and C purposes as specified above.
The Data Controller will process Personal Data properly and shall take appropriate security measures to prevent destruction, unlawful or inappropriate use and unauthorized access to said Personal Data. In particular, the Data Controller will use:
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firewall, such as protection systems that prevent unauthorized access to corporate information system;
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data encryption, such as methods to mask the data and information when data are sent or received in order to make them deciphered only to the intended recipient;
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digital certification;
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further electronic or automatic tools suitable to ensure protection and confidentiality of data, according to the Personal Data Protection Code.
In particular, the Data Controller shall enhance and adopt all such technical, IT, organizational, logistics and procedural security measures granting at least the minimum level of protection required under the Personal Data Protection Code. This will guarantee the level of Personal Data protection required by the law, thus limiting access to Personal Data only to those persons appointed and authorized by the Data Controller.
Collection of information and processing methods will be carried out properly and any Personal Data shall be managed and protected in environments so to ensure a full control on them.
The security systems adopted shall prevent public and discriminatory access to the information uploaded on the Site and collected by Starteed, unless access is through specific registration and authentication procedures.
In addition to the Data Controller, in some cases, Personal Data may be accessible to those involved in the site operation (administration, sales, marketing, legal, system administration), or external third parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by the Data Controller. The updated list of these parties may be requested to the Data Controller at any time.
The processing of Personal Data related to online services provided through the Site are executed at the offices of Starteed, that manages and stores, for the maximum period allowed by the law unless otherwise expressly provided, all or some data using Amazon Web Servicies, licensed by AWS Ireland Ltd., whose servers are located in the Ireland or in other countries as indicated at https://aws.amazon.com.
Further information may be requested to the Data Controller as indicated in article 8 of this Privacy Policy.
In any case, further details on data processing and third parties’ services used to collect Personal Data are directly available at www.starteed.com/thirdparty www.starteed.com/thirdparty
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Personal Data may be disclosed to third parties
Users’ Personal Data will be communicated to the crowdfunding or crowdcreation campaign promoter or manager indicated in this Site, or to his representatives, who shall be deemed an autonomous data controller. The purpose of said communication, and its limits, is to ensure a correct and efficient campaign management, and in particular to provide the Users with updates on the status of the campaign, and to deliver them the related rewards, always within the limits, terms and conditions and for the purposes expressly indicated.
Users’ Personal Data, may also be communicated for the purposes specified under article 5 above, and only as long as it will be strictly necessary to complete each activity, to the following parties:
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companies responsible for audit and control on behalf of Starteed;
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employees, advisors and consultants of Starteed and/or its clients and/or partners engaged in activities within Starteed’s corporate purpose;
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entities engaged to archive documents in any way related to relationships with Users;
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companies engaged in surveys on services quality and level of customer satisfaction;
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third parties’ technical services suppliers;
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banks and payment providers.
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The list of the above mentioned third parties shall be kept updated and will be made available, upon express request to Starteed.
Furthermore, in relation to the type C purposes as specified under article 5 above, Users’ Personal Data may be communicated and/or transferred also to
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third parties with which Starteed from time to time will enter into trade agreements, partnerships, or a common project or initiative, including managers or promoters of crowdfunding and crowdcreation campaigns;
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holding and subsidiary companies or other companies related to Starteed, transferees of company or business unit, companies resulting from the merger, acquisition or demergers.
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Data subjects’ rights
The data subject shall have at any time the right to obtain confirmation as to whether or not Personal Data concerning him exist, and to be informed on their content and source, as well as the right to verify the accuracy of his Personal Data and to obtain updating, rectification, erasure or blocking, according to article 7 of the Personal Data Protection Code.
Requests must be submitted, pursuant t article 8 of Personal Data Protection Code, to Starteed at privacy@starteed.com
The data subject shall have the right to:
The data subject shall have the right to object, in whole or in part:
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the source of the Personal Data;
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the purposes and methods of the processing;
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the methods applied to the processing, if the latter is carried out with the help of electronic means;
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companies engaged in surveys on services quality and level of customer satisfaction;
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third parties’ technical services suppliers;
The data subject shall have the right to:
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obtain updating, rectification or, where interested therein, integration of the Personal Data;
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obtain deletion, anonymization or blocking of Personal Dataata that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
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to obtain certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which Personal Data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
The data subject shall have the right to object, in whole or in part:
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on legitimate grounds, to the processing of their Personal Data, although they are relevant to the purpose of the collection;
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to the processing of Personal Data concerning him, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
