Newsletter Policy

CloudFire Srl (VAT number/tax code) IT02764700353), with registered office in Reggio Emilia (RE) at Via Giambattista Vico 93, ordinary e-mail address info@cloudfire.it, certified e-mail address cloudfire@legalmail.it, owner of the website https://www.cloudfire.it/ (hereinafter, the”Site”), acting as owner of the processing of personal data of users of the Newsletter service (hereinafter, the”Users”) provides below the privacy policy pursuant to art. 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter,”Regulation”, or the”Applicable Legislation”).

This Newsletter service is reserved for individuals who have reached the age of eighteen. The Data Controller therefore does not collect personal data relating to individuals under 18 years of age. At the request of Users, the Data Controller will promptly delete all personal data unintentionally collected and relating to individuals under 18 years of age.

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

• By sending a registered letter with return receipt to the registered office of the Data Controller with registered office in Reggio Emilia (RE) at Via Giambattista Vico 93;
  
• By sending an e-mail message to the following addresses: email: info@cloudfire.it ; PEC: cloudfire@legalmail.it
  

or the Data Protection Officer, Avv. Andrea Ruffilli

• By sending a registered letter with return receipt to the studio in Maranello (MO), Via Garibaldi n. 2
  
• By sending an e-mail message to the following e-mail address: info@studiolegaleruffilli.com.

‍

1. Purposes of the treatment

Users' personal data will be lawfully processed by the Data Controller pursuant to art. 6 of the Regulation for the following processing purposes:

Fulfill the User's request: personal data are collected and processed by the Data Controller for the sole purpose of ascertaining the identity of the User (also by validating the e-mail address), thus avoiding possible scams or abuses and to fulfill the User's request relating to the sending of the newsletter. Therefore, the User will receive from the Data Controller a periodic newsletter containing information in relation to relevant news for the sector relating to the activities of the Data Controller or, to present offers, promotions and commercial opportunities of the Data Controller. The User data collected by the Data Controller for this purpose include: name, surname and e-mail address. No other processing will be carried out by the Data Controller in relation to Users' personal data. Notwithstanding what is provided elsewhere in this privacy statement, under no circumstances will the Data Controller make Users' personal data accessible to other Users and/or third parties;

However, it is always possible to request the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

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 receive the newsletter from the Data Controller. In case of consent, the User may revoke it at any time, making a request to the Data Controller in the manner indicated in paragraph 5 below.

The User can also easily object to further newsletter submissions even by clicking on the appropriate link for revoking consent, which is present in each e-mail containing the newsletter. Once the consent has been revoked, the Data Controller will send the User an e-mail message to confirm the revocation of the consent.

‍

2. Methods of processing and data storage times

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

Users' personal data will be kept for the time strictly necessary to carry out the primary purposes illustrated in the previous point 1) or in any case as necessary for the civil protection of the interests of both Users and the Data Controller.

‍

3. Scope of communication and dissemination of data

The Data Controller's collaborators in charge of managing the newsletter service and Users' requests may become aware of Users' personal data. These subjects, who have been instructed in this regard by the Data Controller pursuant to art. 29 of the Regulation, will process the User's data exclusively for the purposes indicated in this information and in compliance with the provisions of the Applicable Legislation.

Third parties who may process personal data on behalf of the Data Controller as” may also become aware of Users' personal data.External Data Processors”, such as, by way of example, providers of IT and logistics services functional to the operation of the service, service providers in outsourcing or Cloud Computing, professionals and consultants.

Users have the right to obtain a list of any data processors appointed by the Data Controller, making a request to the Data Controller in the manner indicated in paragraph 5 below.

‍

4. Extra EU transfers

The processing does not take place in non-EU countries.

However, it reserves the right to use cloud services; in which case, service providers will be selected from among those who provide adequate guarantees, as required by art. 46 GDPR 2016/679.

‍

5. Rights of Data Subjects

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

• By sending a registered letter with return receipt to the registered office of the Data Controller with registered office in Reggio Emilia (RE) at Via Giambattista Vico 93;
  
• By sending an e-mail message to the following addresses: email: info@cloudfire.it ; PEC: cloudfire@legalmail.it
  

or the Data Protection Officer, Avv. Andrea Ruffilli

• By sending a registered letter with return receipt to the studio in Maranello (MO), Via Garibaldi n. 2
  
• By sending an e-mail message to the following e-mail address: info@studiolegaleruffilli.com.
  

Pursuant to the Applicable Regulations, the Data Controller informs that Users have the right to obtain an indication (i) of the origin of personal data; (ii) of the purposes and methods of processing; (iii) of the logic applied in the case of processing carried out with the aid of electronic tools; (iv) of the identification details of the owner and managers; (v) of the subjects or categories of subjects to whom personal data may be communicated or who may become aware of it as managers or agents.

In addition, Users have the right to obtain:

1. Thelogon, theupgrading, the Rectification that is, when they are interested in it, thesupplementation of the data;
   
2. The erasing, the transformation into anonymous form Or the pad data processed in violation of the law, including those whose storage is not necessary in relation to the purposes for which the data were collected or subsequently processed;
   
3. the attestation that the operations referred to in numbers 1. and 2. have been brought to the attention, also with regard to their content, of those to whom the data were communicated or disseminated, except in the case in which this fulfillment proves impossible or involves the use of means that are clearly disproportionate to the protected right.
   

In addition, Users have:

1. the right to Revoke consent at any time, if the processing is based on their consent;
   
2. the right (where applicable) to data portability (right to receive all personal data concerning them in a structured format, commonly used and readable by an automatic device), the right to restriction of treatment of personal data and the right to cancellation ('right to be forgotten');
   
3. the right to object:
   
   1. in whole or in part, for legitimate reasons to the processing of personal data concerning them, even if relevant to the purpose of the collection.
      
   2. if they believe that the treatment concerning them violates the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State where they usually reside, in the one in which they work or in the one where the alleged violation occurred). The Italian Supervisory Authority is the Guarantor for the protection of personal data, with headquarters in Piazza Venezia 11, 00186 — Rome (http://www.garanteprivacy.it/).
      

For anything not provided for in this information, please refer to Regulation (EU) 2016/679, to Legislative Decree 196/03 as amended by Legislative Decree 101/2018 and subsequent amendments, as well as to any other measure issued by the Guarantor Authority for the Protection of Personal Data (“Guarantor”).

The Data Controller is not responsible for updating all the links that can be viewed in this Policy, so 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 that link. In case of non-acceptance of the changes made to this privacy policy, the User is required to cease using https://www.cloudfire.it/ and may request the Data Controller to remove their Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to Personal Data collected up to that time.