Privacy Policy
1) Definitions
Cookies, Personal Data, Service Contract, Information, Regulation, Service, Additional Services, Site, Processing, Users, Registered Users.
1.1 Cookies: Cookies are text files (letters and/or numbers) that contain packets of information that are stored on the User’s computer or mobile device every time they visit a website through a browser. At each subsequent visit, the browser sends cookies to the website that originated them. Cookies can be stored only for the time of use of a specific site (i.e. session cookies), or for a longer period of time independent of the session (i.e. persistent cookies).
1.2 Personal Data: any information relating to a natural person, identified or identifiable, directly or indirectly, by reference to the name, an identification number, location data, an online identifier or elements characteristic of his physical identity , physiological, genetic, psychic, economic, cultural or social.
1.3 Service Contract: the contract signed by AdHub with the Registered Users for the provision of the Service.
1.4 Information: this document, consisting of the information on the processing of Personal Data and the information relating to Cookies.
1.5 Regulation: EU Regulation 2016/679 of 27 April 2016.
1.6 Service: service for enhancing the spaces of advertising campaigns on sites made available by Registered Users.
1.7 Ancillary Services: right to send spontaneous applications to work with AdHub and to request contact information from AdHub, by completing the form on the Site.
1.8 Site: this site.
1.9 Processing: any operation or set of operations concerning Personal Data, such as, by way of example, collection, organisation, structuring, conservation, modification, extraction, consultation, use, communication, interconnection, limitation, cancellation and destruction.
1.10 Users: users of the Site, including Registered Users.
1.11 Registered Users: users registered on the Site who have a personal account to access the services offered by AdHub with the Services Contract.
2) Data Controller
AdHub Media S.r.l.
The data controller referred to in this Information is AdHub Media S.r.l., with registered office in Via Paolo da Cannobio, 9, 20122 Milan, VAT number no. 13542920965 (“AdHub”). Any request from Users/Registered Users relating to the Processing carried out by AdHub concerning their Personal Data (including the exercise of the rights referred to in the following point 8) must be addressed to AdHub by post at the registered office, or by e-mail to the following address info@adhubmedia.com.
3) Purpose and legal basis of the Processing
a) navigation on the Site: consent;
b) provision of Ancillary Services: consent;
c) access to the personal account by Registered Users: Services Contract;
d) improvement of the Site: legitimate interest.
AdHub collects and uses the Personal Data of Users/Registered Users to achieve the following purposes:
a) Allow navigation on the Site, essentially through the use of Cookies.
➢ The collection of Personal Data for the purposes referred to in letter a) is regulated in the Cookies Policy, available at the following link cookie-policy , which AdHub recommends reading.b) Provide the Ancillary Services to the Users.
➢ The collection of Personal Data for the purposes referred to in letter b) is necessary for the User to use the Accessory Services and any refusal prevents the User from using the Accessory Services. This Processing is based on the free, specific, informed and unequivocal consent of the User, expressed through a declaration or positive action (e.g. flag) on the Site. The withdrawal of consent can be exercised at all times, following the instructions referred to in point 7 letter. a) of this Information.c) Allow Registered Users to access their personal accounts to use the Service.
➢ The collection of Personal Data for the purposes referred to in letter c) is necessary for the use of the Service by Registered Users, according to the terms and conditions set out in the Service Contract and any refusal prevents Registered Users from using the Service itself. This Processing is based on the signing of the Service Contract.d) Perform statistical analyzes on the use of the Site, to improve the Site. Where possible, to achieve this purpose AdHub uses anonymous Personal Data (Personal Data that does not identify or make the Users identifiable).
➢ The Processing referred to in letter d) is based on the legitimate interest of AdHub consisting of the benefit that the Company can obtain from the preparation of a Site that facilitates navigation and improves the Users’ experience, which AdHub believes be prevalent over the Users’ right to privacy. The opposition to this Processing (if it does not concern anonymous data) can be exercised at any time by following the instructions referred to in point 7 letter. g) of this Information.
4) Data collection methods
a) Personal Data collected automatically by the Site (via Cookies);
b) Personal Data entered on the Site by Users;
c) Personal Data expressly communicated to AdHub by Users offline.
AdHub collects Personal Data in the following ways:
a) Personal Data collected automatically by the Site: these are Personal Data collected automatically by the Site through, but not limited to, Cookies (for further information, AdHub recommends reading the Cookies Policy below);
b) Personal Data entered on the Site by Users: are the Personal Data provided by Users to use the Accessory Services, for example through the contact form at the link: contacts.
c) Personal Data expressly communicated to AdHub by Users offline: these are Personal Data directly communicated to AdHub employees and collaborators by Users through methods other than the Site.
5) Any categories of recipients of Personal Data
Employees, collaborators, third party IT service providers, third parties contractually linked to AdHub (for the provision of the Services).
Personal Data is processed by AdHub and/or by third parties, selected for reliability and competence, and to whom they may be communicated as necessary or appropriate, provided that they are within the European Union. In particular, AdHub informs Users that Personal Data may be processed by, and/or communicated to:
a) AdHub employees and/or collaborators;
b) third party suppliers of services necessary to guarantee the functioning of the Site (for example: companies that provide hosting services, IT technicians);
c) third parties who provide site navigation data analysis services;
d) third parties, contractually linked to AdHub, necessary for the provision of the services referred to in the Service Contract (e.g. territorial partners of AdHub).
6) Personal Data retention period (or criteria for determination)
a) Personal Data from the “contact” form: 3 months from receipt of the request;
b) Personal Data for the account: for the duration of the Services Contract.
Personal Data is retained by AdHub for the period of time strictly necessary to achieve the purposes for which it was collected, as indicated in point 3 above. In particular, unless the right to withdraw consent is exercised pursuant to the following point 8 letter. a) and the right of opposition referred to in point 8 letter. g), AdHub retains Personal Data for the following duration:
a) Cookies: for the purposes referred to in point 3 letter a), we recommend reading the cookies information;
b) Personal Data collected from the “contacts” form: for the purposes referred to in point 3 letter b), for the period of 3 months from receipt of the contact request, in order to verify whether the User needs further assistance on the same topic. As an exception to this deadline, in the event of sending a complaint or grievance via the “contact” form, the User’s Personal Data will be retained for the period referred to in the following letter d);
c) Personal Data for the management of the Registered Users’ account: for the purposes referred to in point 3 letter c), for the duration of the Services Contract;
d) in any case, AdHub is authorized to retain, in whole or in part, Personal Data for a maximum period of 10 years from collection, limited to the information necessary to fulfill legal obligations and allow AdHub itself to ascertain, exercise and defense of one’s right in court.
Once these terms have expired, AdHub will automatically delete the Personal Data collected, or transform them into anonymous form in an irreversible manner.
7) Rights of Users/Registered Users
Revocation of consent, access to Personal Data, rectification or integration of Personal Data, deletion of Personal Data, limitation of Processing, opposition to Processing, portability of Personal Data, data breach, complaint to the competent authorities
Pursuant to and for the purposes of the Regulation, for the period referred to in point 6 of this Information, each User/Registered User has the right to:
a) with reference to the Processing referred to in point 3 letter. b), revoke consent at any time without prejudice to the lawfulness of the Processing, by sending an email to AdHub or by exercising the opt-out in AdHub’s commercial communications (see art. 7 of the Regulation); >
b) ask AdHub for access to the Personal Data and information on the related Processing and any copy in electronic format, unless specifically requested otherwise by the Users/Registered Users (see art. 15 of the Regulation);
c) request the rectification and/or integration of Personal Data, without unjustified delay (see art. 16 of the Regulation);
d) for specific reasons (for example, illicit processing, revocation of consent, non-existence of the purpose of the Processing), request the deletion of Personal Data, without unjustified delay (see art. 17 of the Regulation);
e) in the event of the occurrence of specific hypotheses (for example, inaccuracy of the Personal Data, unlawfulness of the Processing, exercise of a right in court), request the limitation of the Processing (art. 18 of the Regulation);
f) receive the Personal Data concerning him in a structured, commonly used and readable format and, consequently, exercise the right of portability and transmit such data to another owner (art. 19 of the Regulation);
g) with reference to the Processing referred to in point 3 letter d), object at any time to the Processing of Personal Data by sending an email to AdHub (see art. 21 of the Regulation);
h) be informed by AdHub without unjustified delay of any violations or unauthorized access by third parties to its systems containing Personal Data (so-called data breach – art. 34 of the Regulation);
i) lodge a complaint with the supervisory authority of the EU country in which you reside, work or where you believe the violation of your rights has occurred (see art. 77 of the Regulation);
For further information regarding the terms and conditions for the exercise of the rights recognized to Users/Registered Users, the latter can consult the text of the EU Regulation published at the following link http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN, or contact AdHub in the ways provided for in point 2 of this Policy.