Last update: 14/07/2018
“Personal data” (ex art. 4 no. 1 of GDPR) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” (ex art. 4 no. 2 of GDPR) means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Who are we and how can you contact us?
Headquarter address: Via Morozzo Della Rocca, n. 8, 20123 Milano
Phone: +39 02 36752234
Email: [email protected]
Data processing in relation to registration page
Personal Data collected
Personal data collected regard:
- Identification data (name, surname, e-mail);
- Personal data (profession, address, city, ecc.).
- Fulfillment of legal obligations, regulations, italian and european law;
- Registration to the site to permit the use of services and to allow the downloading of 3D models, BIM objects, textures and 3D libraries. By consenting to the registration, the data subject consents to our system to track the navigation in the website that allows to understand the area of his interest (see the details below);
- Marketing activities carried out by the Data Controller, also on behalf of our partners producing architectural materials and furnishing products for architecture for the purpose of sending catalogs, samples, informations and promotions;
- Marketing activities carried out by the Data Controller, also on behalf of our partners producing architectural materials and furnishing products for architecture in order to send DEM and newsletters with profiled content based on the interests expressed;
- communicate / transfer identification or contact data to our partners, for which the data subject has expressed interest, so that the same producer can send promotional and informative messages, as well as contact the data subject to start projects or establish working relations;
- internal statistical analysis in aggregate form.
The following table specifies for each above identified purpose, lawfulness of processing, categories of personal data, categories of data subjects and period for which the personal data will be stored:
Purposes of the processing
Legal basis for the processing
Type of personal data
Categories of recipient
Identification and personal data
Until the request to cancellation from the service
Identification and personal data
|Registration maintained until the request of cancellation / withdrawal of consent. The last 100 activities are tracked, on a window of the last 2 years||
Identification and personal data
Until 24 months
Identification and personal data
Until 24 months
Personal data are maintained and available for partners until the request of cancellation / withdrawal of consent. For further details, read the informative note of the partner
(only in case of consent to registration)
|In 1 year, personal data will be transformed into an anonymous and aggregate form||
*Categories of recipient
In relation to the mentioned purposes, personal data could be communicated to the following companies and/or persons, located in UE countries, which provide services, also external, on behalf of the Data Controller. Among which**, in order to clarify, we just give an example, not as an exhaustive list:
- Accounting and legal consultant;
- IT services company;
- Communication agencies;
- Consulting societies in marketing area;
- partners producing architectural materials and furnishing products for architecture (if the data subject has given consent);
- Supervisory bodies.
(**) Recipients / Processors list with additional data useful for the purpose of identification, is available at the Data Controller.
Personal data transfer to a country extra-UE
Data Controller does not transfer personal data out of UE countries.
Period for which the personal data will be stored
Please refer to Table 1 column 4 (storage period). With reference to the aim in point 2, it’s specified that Syncronia's goal is to get the designers accustomed to the use of certain brands in their design activities. Taking into account that many product categories are only occasionally used in projects, the period useful for detecting a stable use / interest of the product is at least 2 years. The observation of a shorter period would be less effective than the objective and could generate a large number of "false positives", detecting untrue interests.
Data subject rights
With reference to the abovementioned data processing, the data subject can exercise the following rights provided by GDPR:
- Right of access by the data subject [art. 15 of the GDPR];
- Right to rectification [art. 16 of the GDPR];
- Right to erasure (‘right to be forgotten’) [art. 17 of the GDPR];
- Right to restriction of processing [art. 18 of the GDPR];
- Right to data portability [art. 20 of the GDPR];
- Right to object [art. 21 of the GDPR];
- Right not to be subject to a decision based solely on automated processing [art. 22 of the GDPR].
The aforementioned rights may be exercised according to the provisions of the Regulations by sending an email to [email protected]
If the purpose of processing pursued by
If data subject considers that his rights have been compromised, he has the right to lodge a complaint with a supervisory authority.
For further information about rights and how exercise them, please refer to "Legal references about rights of data subject"
Automated individual decision-making
A decision based solely on automated processing, including profiling, which produce legal effects concerning the data subject or similarly significantly affects him or her, is lawful only in the cases foreseen and regulated by the art. 22 of the EU Regulation, like:
- It’s necessary for entering into, or performance of, a contract between the data subject and a data controller;
- It is authorised by Union or Member State law to which the Data Controller is subject;
- It is based on the data subject’s explicit consent.
Regarding to the purpose of point 2, the Data Controller asks the consent to the data subject, registered on the site, before starting a profiling activity based on his navigation. This is required for the only purpose of providing a free service to the Data Sybject. Also, Data Controller wants to remember that the site is not paid. Furthermore, the profiling activity allows the Data Subject the possibility of being sponsored by the Data Controller to his partners and customers, as well as receiving targeted information and promotions, based on the preferred products (see purpose 4). The Data Subject, at any time, may request cancellation from this site and his/her data will no longer be processed.
We specify that Syncronia's activity also consists in organizing the follow-up activity of the companies, directing it towards the most interested contacts and taking advantage of the moment in which an actual product prescription is detected in the project. It is in the interest of all the parties involved (Syncronia, the producer and the designer) that contact activities take place, in addition to respecting the authorizations / consent provided by the user, even when it is useful to activate them. Moreover, even the period of retention of personal data of at least two years, allows Syncronia to activate contacts, only in the case of real and demonstrated interest by users / architects / planners, such a way as to not perform spam activities to a category that already receives 30 contact attempts per day, on average, by promoters / sellers.
Modalities of the processing
Personal data will be processed in paper, digital and telematic form and inserted in the applicable data banks (clients, potential clients, ecc.), which can be consulted and processed by the operators and processors designated by the Data Controller who will be able to carry out the consultation, use, handling, comparison and any other appropriate operation, direct or automatic, respecting the legal requirements necessary to guarantee the confidentiality and the security of the data, as well as their accuracy, updating, and their relevancy to the declared aims. With reference to the purpose in point 3, at any time the data subject can proceed to unsubscribe by sending an email to [email protected] or by clicking on the link at the bottom of the email. With reference to the purpose in point 5, some data may be communicated anonymously and aggregated to group companies or third parties for statistical purposes. For example, the average age of visitors to the site, the number of visitors coming from different geographical areas, can be communicated. In any case, they are not data that allow the identification of Users.
Handling of data useful for navigation purposes
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified.
Among the information that can be collected we have the IP addresses, the type of browser or the operating system used, the addresses in notation URI (uniform resource identifier), the domain name and the addresses of the websites from which the access or exit (referring / exit pages), the time at which the request was made to the server, the method used and information on the response obtained, further information on the user's navigation on the site (see also the related section to cookies) and other parameters relating to the operating system and the user's computer environment.
These same data could also be used to identify and ascertain responsibilities in case of any computer crimes against the site.
WHAT ARE COOKIES?
Cookies are small text strings that a website can send, while browsing, to your device (be it a PC, a notebook, a smartphone, a tablet, usually stored directly on the browser used for navigation) . The same website that transmitted them, then can read and record cookies that are on the same device in order to obtain information of various kinds. Which? For each type of cookie there is a well-defined role.
HOW MANY TYPES OF COOKIES DO EXIST?
There are two basic macro-categories, with different characteristics: technical cookies and profiling cookies.
Technical cookies are generally necessary for the proper functioning of the website and to allow navigation; without them you may not be able to view the pages correctly or use some services. For example, a technical cookie is essential to keep the user connected throughout the visit to a website, or to store the language, display, and so on. Technical cookies can be further distinguished in:
• navigation cookies, which guarantee the normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas);
• analytics cookies, similar to technical cookies only when used directly by the website operator to collect information, in aggregated form, on the number of users and the way they visit the site.
• functionality cookies, which allow the user to navigate according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.
Profiling cookies are more sophisticated! These cookies have the task of profiling the user and are used in order to send advertising messages in line with the preferences expressed by the user during his navigation. Cookies can still be classified as:
• session cookies, which are deleted immediately when the browser is closed;
• Persistent cookies, which - unlike session cookies - remain in the browser for a certain period of time. They are used, for example, to recognize the device that connects to the site facilitating authentication operations for the user
• first-party cookies (first-part cookies) or cookies generated and managed directly by the manager of the website on which the user is browsing.
• third-party cookies (third-part cookies), which are generated and managed by parties other than the operator of the website on which the user is browsing (in force, as a rule, a contract between the owner of the website and the third part).
WHICH TYPES OF COOKIES DOES Syncronia S.r.l. USE?
(A) Technical cookies set by the Website www.syncronia.com
Name of the cookie ASPSESSIONID or PHPSESSID. Purpose of the cookie is to facilitate the navigation of the site by memorizing the navigation settings chosen by the user.
(B) Third-party cookies on the Website www.syncronia.com
Facebook Connecthttps://www.facebook.com/policy.phpWidget Facebook Custom
Audiencehttps://www.facebook.com/policy.phpRemarketing Facebook Social
Google Analyticshttp://www.google.it/intl/it/policies/privacy/Analytics Google Dynamic
Google Plushttps://www.google.com/intl/en/+/policy/pagesterm.htmlWidget Google Tag
(C) Flash cookies or LSO (Local shared objects)
On the www.syncronia.com website, sometimes video content is displayed using Adobe Flash Player. Adobe uses flash cookies, also called LSO (Local Shared Objects), to improve the user experience. Flash cookies are stored on your computer or mobile phone in ways similar to those of normal cookies. However, the browser handles them differently. If you wish to deactivate or delete a flash cookie, refer to the Security settings of Adobe Flash Player (a new window will open). However, please note that disabling flash cookies will deny you access to certain types of content such as videos.
(D) SITE sharing tools
If you decide to share the contents of the SITE with your friends through social networks, these websites may send you cookies. We are not able to control the setting of these cookies, so we suggest you to visit the relevant websites to get more information about their cookies and how to manage them. By changing your browser settings, you can accept or reject cookies or decide to receive a warning from the website before accepting a cookie. It is possible to delete all the cookies installed in the browser’s cookies folder. Each browser has different procedure for managing settings. Please use the links below to find specific instructions for the most common browser:
Notice concerning minors of 16 years old
Exercise of data subjects rights
Change and updates
Legal references about rights of data subject
Right of access by the data subject
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
(a) the purposes of the processing;
(b) the categories of personal data concerned;
(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
(e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
(f) the right to lodge a complaint with a supervisory authority;
(g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
2.Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
3.The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
4.The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
Right to rectification
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure (‘right to be forgotten’)
1.The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
(c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
(d) the personal data have been unlawfully processed;
(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
(f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1). 2.Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
3.Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(e) for the establishment, exercise or defence of legal claims.
Right to restriction of processing
1.The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
(a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
(b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
(c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
(d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
2.Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3.A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
Notification obligation regarding rectification or erasure of personal data or restriction of processing
The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.
Right to data portability
1.The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where: (a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and (b) the processing is carried out by automated means.
2.In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
3.The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
4.The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
Right to object
1.The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
2.Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3.Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4.At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information. 5.In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications. 6.Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
Automated individual decision-making, including profiling
1.The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
2.Paragraph 1 shall not apply if the decision: (a) is necessary for entering into, or performance of, a contract between the data subject and a data controller; (b) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or (c) is based on the data subject's explicit consent.
3.In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
4.Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject's rights and freedoms and legitimate interests are in place.