Privacy Policy

This privacy policy aims to provide all information on the processing of personal data carried out by SNAP- Marketing when the User accesses and navigates this platform (as better indicated below).

1. INTRODUCTION - WHO ARE WE?

SNAP- Marketing S.r.l. with registered office in Via MENFI (AG) VIA VITTORIO VENETO 20 CAP 92013, Tax Code/VAT no. 03110110842 (hereinafter, “Data Controller”), owner of this website and/or digital channels (hereinafter, “Digital Channels”), acting as the data controller of the personal data of users who browse the Digital Channels and who register through the Forms provided via the Digital Channels (hereinafter, “Users”) provides below the privacy policy pursuant to art. 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter, “Regulation”, or “Applicable Law”).

2. HOW TO CONTACT US?

The Data Controller highly values the right to privacy and the protection of personal data of its Users. For any information in relation to this privacy policy, Users can contact the Data Controller at any time, using the following methods:

• By sending an email to: privacysnap@creationdose.com 

• By sending a certified email to: snap-marketingsrl@legalmail.it 

The Data Controller has not appointed a Data Protection Officer (DPO), as it is not subject to the designation obligation provided for by art. 37 of the Regulation.

3. WHAT DO WE DO? – PURPOSES OF THE TREATMENT

The User can browse the available content and learn about the services and initiatives promoted by the Data Controller. In relation to the activities that may be requested, the Data Controller collects personal data relating to the Users. In particular, the personal data of the Users will be processed lawfully by the Data Controller for the following purposes:

a) Allow navigation. The user data collected by the Data Controller for the sole purpose of navigation include all those personal data whose transmission is implicit in the use of Internet communication protocols, such as: IP addresses used by users connecting to the digital channels, the URI (Uniform Resource Identifier) notation 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, log files, and other parameters relating to the User's operating system and computer environment.

b) Contact and/or information request. The user data collected by the Data Controller for the purpose of any contact request and/or information request include: name, surname, e-mail address, phone number, company email, company name, company website, telephone number, business type (brand, ecommerce, agency, media center, other), job title (CEO, MKT, Social, Account, other), referral (google, dm, ads, social, other), as well as any personal information of the User voluntarily published. The personal data of the User will be used by the Data Controller for the exclusive purpose of verifying the identity of the User, thus avoiding possible fraud or abuse, and contacting the User for service-related reasons only (e.g. to reply with regard to their request for information). Without prejudice to what is provided elsewhere in this privacy policy, under no circumstances will the Data Controller make the personal data of Users accessible to other Users and/or third parties.

c) Business Review and Subscription Services (Form "Snap Review" and "Subscribe"): collection and analysis of specific data such as company email, company name, company website, phone number, business type, job title, marketing objectives, referral, social profiles, city of origin, place and date of birth. This data is processed to evaluate the establishment of professional collaborations and provide technical feedback on the User's business performance.

d) Compliance with legal obligations, consisting of fulfilling obligations provided for by law, an authority, a regulation, or European legislation.

The Data Controller's Digital Channels and any services offered through them are restricted to individuals who have reached eighteen years of age. In the event of data collection from a minor, upon request, the Data Controller will promptly delete all personal data involuntarily collected and relating to individuals under 18 years of age. 

The provision of personal data for the processing purposes indicated above is optional but necessary, since failure to provide them will make it impossible for the User to use the services offered by the Data Controller.

The personal data necessary for the processing purposes described in this paragraph 3 are marked with an asterisk in the request form. 

4. ADDITIONAL PURPOSES OF PROCESSING

Newsletter and Commercial and/or Promotional Communications 

Some personal data of the User (i.e. name, surname, email address, phone number) may also be processed by the Data Controller for the purpose of sending the newsletter. Therefore, the User will receive a periodic newsletter from the Data Controller containing information regarding updates, news, and initiatives related to the Digital Channels and/or the Data Controller.

In case of lack of consent, the ability to browse the Digital Channels of the Data Controller will not be affected in any way.

In case of consent, the User may withdraw it at any time by making a request to the Data Controller in the ways indicated in the subsequent paragraph 8.

The User will also be able to easily object to further mailings of promotional communications by clicking on the appropriate link to revoke consent, which is present in each email containing the newsletter. Once the revocation of consent has been carried out, the Data Controller will show the User a confirmation message of the successful withdrawal of consent.

LEGAL BASIS

Contractual obligations and fulfillment of User requests (as described in the previous section 3, letters a), b), c): the legal basis consists of art. 6, paragraph 1, letter b) of the Regulation, i.e. processing is necessary for the performance of a contract to which the User is party or for the implementation of pre-contractual measures taken at the request of the same.

Legal obligations (as described in the previous section 3, letter d)): the legal basis consists of art. 6, paragraph 1, letter c) of the Regulation, as processing is necessary for compliance with a legal obligation to which the Data Controller is subject.

Additional purposes of processing: for processing related to the activity of sending the newsletter (as described in the previous section 4.1)), the legal basis consists of art. 6, paragraph 1, letter a) of the Regulation, i.e. the consent given by the data subject to the processing of their personal data for one or more specific purposes. For this reason, the Data Controller asks the User for a specific, free, and optional consent to pursue this purpose of processing.

PROCESSING METHODS AND DATA RETENTION PERIODS

The Data Controller will process the personal data of Users using manual and computer tools, with logic strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security and confidentiality of the data themselves.

The personal data of Users will be kept for the time strictly necessary to fulfill the primary purposes illustrated in the previous paragraph 3, or in any case as necessary for the civil protection of the interests of both the Users and the Data Controller.

In the case referred to in the previous paragraph 4.1, the personal data of Users will be kept for the time strictly necessary to fulfill the purposes illustrated therein and, in any case, until the User withdraws their consent.

Pursuant to data protection law, if we have no legitimate reason to continue storing your data, you have the right to be forgotten.

In any case, any retention periods provided for by laws or regulations remain unaffected.

SCOPE OF COMMUNICATION AND DISSEMINATION OF DATA

The employees and/or collaborators of the Data Controller in charge of managing the Digital Channels and responding to User requests may become aware of the personal data of the Users. These subjects, who have been instructed to this effect by the Data Controller pursuant to art. 29 of the Regulation, will process the Users' data exclusively for the purposes indicated in this policy and in compliance with the provisions of the Applicable Law. 

Furthermore, third parties who may process personal data on behalf of the Data Controller as Data Processors may become aware of the Users' personal data, such as, by way of example, IT and logistics service providers functional to the operation of the Digital Channels, outsourcing or cloud computing service providers, professionals, and consultants.

Users have the right to obtain a list of any data processors appointed by the Data Controller, by making a request to the Data Controller in the ways indicated in paragraph 8 below.

The Data Controller makes every reasonable effort to ensure the absolute security of all systems that make up our website, database, and e-commerce mechanisms, as well as the workstations accessing these systems for administration and analysis.

We take all necessary measures to ensure that our systems and those of our service providers are physically and electronically secure. All company and affiliated systems are password protected. All transmissions of sensitive information, from customer workstations to web and e-commerce servers, as well as from processing and storage systems and company systems to administration workstations, are fully encrypted.

For security reasons, we inform you that we use information about you and your use of the Service to verify accounts and activities, to monitor suspicious or fraudulent activity, and to identify violations of Service policies. To protect our legitimate business interests and legal rights, where required by law or where we believe it is necessary to protect our legal rights, our interests, and the interests of others, we use information about the User in connection with legal claims, compliance, regulatory and audit functions, and disclosures in connection with the acquisition, merger, or sale of a business.

With the User's consent, we use information about them in the event that the User has given us consent for a specific purpose not listed above. For example, featured testimonials or customer stories to promote the Services, with your consent.

RIGHTS OF THE INTERESTED PARTIES 

Users may exercise the rights guaranteed to them by the Applicable Law, by contacting the Data Controller in the following ways:

• By sending an email to: privacysnap@creationdose.com 

• By sending a certified email to: snap-marketingsrl@legalmail.it 

The Data Controller has not identified a Data Protection Officer (DPO), not being subject to the designation obligation provided for by Section 37 of the Regulation.

Pursuant to Applicable Law, the Data Controller informs that Users have the right to obtain indication of (i) the origin of the personal data; (ii) the purposes and methods of the processing; (iii) the logic applied in case of processing carried out with the aid of electronic instruments; (iv) the identification details of the controller and processors; (v) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them as processors or persons in charge of processing.

Furthermore, Users have the right to obtain:

a) access, updating, rectification or, when they have interest, integration of data;

b) erasure, anonymization or restriction of data processed in violation of law, including those whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;

c) certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where this fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right.

Furthermore, Users have:

a) the right to withdraw consent at any time, if the processing is based on their consent;

b) the right to data portability (right to receive all personal data concerning them in a structured, commonly used and machine-readable format);

c) the right to object:

i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;

ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication;

iii) if personal data are processed for direct marketing purposes, at any time, to the processing of their data carried out for this purpose, including profiling to the extent that it is related to such direct marketing.

d) if they believe that the processing concerning them violates the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State where they habitally reside, where they work, or where the alleged infringement occurred). The Italian supervisory authority is the Garante per la protezione dei dati personali, located in Piazza Venezia n. 11, 00187 – Rome (http://www.garanteprivacy.it/).

DEFINITION OF "THIRD PARTIES"

For clarity, "third party" is defined as anyone who is not part of the Data Controller's organization nor directly affiliated with it. Directly affiliated subjects include service providers (who, in providing services such as hosting and processing mechanisms for our websites, have access to information contained in their systems) and affiliated retailers and sales partners (who collect customer information on our behalf). Under no circumstances will subjects directly affiliated with the Data Controller use the information disclosed to them for purposes other than providing the information to the Data Controller for the use described in the previous sections.

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The Data Controller is not responsible for updating all the links visible in this Policy, therefore, whenever a link is not working and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to by such link.