Privacy policy, maximum security and respect for your data

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1. Data controller

Hoplo S.r.l., the Data Controller for the Personal Data processed, is the owner of Infomail, an online Platform designed to send communications (email or newsletters) to lists of email addresses owned by the users of Infomail. Hoplo therefore provides the following information about the processing of data that users may disclose or that Hoplo itself may collect when you browse the Hoplo S.r.l. owned Internet Sites or when you use the Platform. This information note is provided pursuant to Art. 13 of Legislative Decree no.196/2003 cd. "Personal Data Protection Code" ("Code") and Art. 13 of the EU Regulation 2016/679 ("GDPR").

2. Definitions

In this privacy policy, the following terms have the meaning indicated below: Website: www.infomail.it Visitor: anyone visiting the Internet Sites owned by Hoplo S.r.l. Customer: the natural or legal person who has created an account (professional or agency) to use our Platform or who uses one of the other services put provided by Hoplo S.r.l (for example, sending the newsletter). Personal Data: the information that identifies or enables the identification of a Client or Visitor (e.g. first and last name, date of birth, e-mail address...) Recipient List / Mailing List: the list of recipients uploaded by a Client to our Platform (consisting mainly, but not exclusively, of e-mail addresses). It is up to the Clients to upload additional personal information about the recipients included in the list (e.g. adding first name, last name or residential address...). Platform/Service: the online platform accessible through the Internet in SaaS ("Software As A Service") mode: the platform allows Clients to independently manage digital marketing campaigns, using different tools and communication channels (email, social...)

3. Methods of processing personal data

Hoplo S.r.l processes personal data using the operations indicated in art. 4 of the Privacy Code and art. 4 no. 2) GDPR and specifically: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction of data. Personal data may be subject to both paper and electronic and/or automated processing.

4. Privacy for visitors

NB: If you are not a Visitor, please refer to the Customers section of this policy. This section is addressed to Users (i.e., those who browse the Sites owned by Hoplo S.r.l) and applies to all Personal Data collected and processed as a data controller.

Data are Processed by the Data Controller

  1. Personal Data that is automatically tracked when you browse the Sites.Technology, software and computer systems underpin our sites and ensure their operation, including through automated procedures, by collecting certain personal data in a manner consistent with the use of Internet communication protocols. These include, for example, the type of browser or device used to access the website, operating system in use, etc.
  2. Personal Data you provide voluntarily when browsing our Websites. On some pages of the Websites, there are form fields where the User may voluntarily provide certain Personal Data (for example name, surname or e-mail) to activate trial accounts, or to send general questions or support requests.

How Personal Data are used by the Data Controller (purposes of processing)

The Data Controller uses Personal Data to:
  1. verify that the methods of use of the site are in line with its purposes;
  2. permit the activation of Service accounts;
  3. answer questions and support requests received;
  4. send communications, for example: newsletters, commercial communications, updates and news, ongoing initiatives, reports;
  5. collect anonymous statistical information on the use of the website.

Legal references for the processing of Personal Data

The legal basis that legitimizes the processing of the Personal Data automatically collected by browsing our Website may be:
  1. the consent freely given by the User when signing our Cookie Policy,
  2. or the legitimate interest in making the Sites’ functions usable following access on the part of the user.

5. Privacy for Customers

NB: If you are not a Customer , please refer to the Visitors section of this policy. This section is for Customers or Potential Customers (i.e. those who use the Platform or Services owned by Hoplo S.r.l) and applies to all the Personal Data collected and processed by the data controller.

Personal Data processed by the Data Controller

  1. Personal Data collected automatically when using the Platform. When a Customer accesses and uses the Platform, the Data Controller may collect the following information:
    1. Platform usage data (e.g. date and time of access to the Platform or tracking of activities performed while browsing);
    2. information on the devices used to access the Platform (for example: IP address, operating system in use, or browser data);
    3. log data (e.g. log files that detect when a device accesses the Owner’s servers, recording the type of each access and the source IP address);
    4. Platform statistics
  2. Personal Information provided voluntarily by the Customer to create an account or purchase our Platform. To access and use the Service, Customers must voluntarily provide certain data to create and activate their account:
    1. registration details (e.g. name, surname, e-mail address, user name, password, company name, address);
    2. administrative and accounting data (e.g. VAT number or billing address).
  3. Personal Data collected automatically when sending e-mails or communications. When sending emails or messages, some tracking systems, (e.g., hidden pixels), are used to detect the opening of a message, clicks made on links (i.e., hyperlinks) in the sent communication, from which IP address or with which type of browser the email is opened, and other similar details.

How Personal Data are used by the Data Controller (purposes of processing)

The Data Controller uses Personal Data to:
  1. provide the services comprised by the Platform’s functions;
  2. improve the quality of the services provided and provide adequate support to Platform users;
  3. carry out monitoring and quantitative analysis on the Platform;
  4. profile Clients in order to identify and predict possible choices and behaviour in the future;
  5. promote the services of Hoplo Srl;
  6. verify compliance with the User License Agreement;
  7. prevent, detect and discourage illegal activities that do not comply with the licensing agreement;
  8. send invoices and administrative communications;
  9. comply with legal provisions or respond to any requests from public authorities;
  10. communicate directly with Customers, by responding to questions and requests and providing assistance and support.

Legal references for the processing of Personal Data

The legal basis that legitimizes the processing of Personal Data provided voluntarily or collected automatically when sending communications and e-mails is the execution of a contract to which the Customer is a party or the execution of pre-contractual measures taken at the Customer’s request. The legal basis for the processing of the Personal Data that are automatically collected during the use of the Platform is the legitimate interest in improving the use of the Platform, to carry out monitoring aimed at conducting research and analysis on the Platform and to prevent illegal or unauthorised activities.

6. Common provisions

Security measures taken Personal Data may be processed using electronic and automated tools, or through manual processing in software based on principles strictly related to the purposes for which the personal data were collected and, in any case, in order to ensure the security of said data. Hoplo applies pseudonymisation and encryption procedures to the personal data stored and stores the data in the cloud, using specially appointed data processors. How long we store your Personal Data retains Personal Data for the time strictly necessary for the purposes for which they were collected, in accordance with current legislation. Hoplo shall process Personal Data for the time necessary to fulfil the above purposes and in any case for no more than 10 years from the termination of the relationship for the Service Purposes and for no more than 2 years from the collection of data for the Marketing Purposes. Authorised parties and data processors The Personal Data of Users and Customers are processed by our specially appointed and authorised employees, in their capacity as internal data managers and/or processors and/or system administrators, and/or external data processors. If necessary for the purposes indicated, the Personal Data collected may be shared with third parties appointed as data processors; these may include: 1.  subjects (persons or companies) that perform services connected and instrumental to the execution of the specific purposes of the services provided by the Platform (for example: market research, credit card payment management, technological maintenance). 2.  subjects (persons or companies) who provide assistance and advice to our Company (for example: IT infrastructure managers, system administrators). With specific consent, Personal Data may be transferred abroad, to companies that may or may not be part of our group of companies, even outside the European Union. In this case, the Data Controller guarantees forthwith that the transfer of the data outside the EU will take place in accordance with the applicable legal provisions, subject to the standard contractual clauses contemplated by the European Commission. In any case, your Personal Data will never be disclosed. What rights apply Users and Customers may have access to their Personal Data, oppose its processing and request the deletion, modification or updating of all the Personal Data stored, exercising the right to limitation of processing and the right to data portability.

7. Rights of Visitors and Customers

Visitors and Customers have the rights set forth in art. 7 of the Privacy Code and art. 15 of the GDPR, and specifically:
  1. to obtain confirmation of the existence of personal data concerning them, and their communication, where requested, in a comprehensible form;
  2. to obtain:
    1. the updating, correction or possible integration of data;
    2. the deletion or anonymisation of data cancellation
  3. to oppose, in full or in part: a) for legitimate reasons, the processing of personal data concerning them, even if pertinent to the purpose of collection; b) the processing of personal data for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator, by e-mail and/or through traditional marketing methods by telephone and/or mail. Visitors and Customers enjoy the rights set forth in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right to limitation of processing, right to data portability, right to object), as well as the right to file a complaint with the Data Protection Authority.

8. How rights can be exercised

Visitors and Customers may exercise their rights at any time by sending an e-mail to privacy@hoplo.com or a PEC certified e-mail to hoplo@legalmail.it