PRIVACY POLICY INFORMATION DOCUMENT

Transcription

1 PRIVACY POLICY INFORMATION DOCUMENT Information pursuant to and for the purposes of Art. 13, Legislative Decree dated 30 June 2003 n. 196 under the Italian Law This document describes how the website manages personal data of visitors and customers who use it. This information is provided to those who interact with web services of the online platform (hereinafter Portal or specifically mentioned WeAreStarting Srl) and it aims at the sole purpose of facilitating the raising of risk capital by innovative companies identified as innovative startup or innovative SMEs (hereinafter Issuers) according to Italian law through the portal associated with the address Personal information provided to register and use the services offered by the portal as well as the additional information obtained from WeAreStarting Srl in accordance with paragraph "Type of data processed," which you will find below, will be processed in accordance with the regulations in force. According to the law (also known as the Privacy Code), this treatment will be based on principles of fairness, legality and transparency and protection of your privacy and your rights. The information applies only to the website of the platform WeAreStarting and is not valid for other Web sites accessed through links available on the Portal. Holder of the process The holder of this process is WeAreStarting Srl, with registered office in Via Giorgio and Guido Paglia, 21/b Bergamo (BG), with a share capital of 20,000 fully paid, registered in the Register of Companies of Bergamo REA n , Tax Code and VAT , represented in person by legal Dott. Gabriele Vittorio Nava, who is also the data controller. Aims of the process The data collected will be used by WeAreStarting Srl, in compliance with the Privacy Code and the consent, exclusively for the purposes listed below: The performance, management and execution of the Services offered by WeAreStarting Srl to registered users of the portal as defined in the Terms and Conditions, including: access to accounts of third-party services, publishing on the Portal and management of contents (documents, information, images, video, certificates, certificates, calculations, etc.) that users voluntarily decide to enter in the specifically designed spaces online, registration and authentication, publication on the portal of information and certificates of issuers, interaction with external social networks and platforms, viewing content from external platforms, statistics, management addresses and sending messages, contact users, social capabilities, hosting and performance testing of content and functionality (A / B testing), management and execution of subscription orders of investors, sending information and publicity purposes relating to WeAreStarting Srl; Management and archiving of documents relating to relations with members; [1]

2 Management of complaints and disputes; Fulfill the obligations set by laws, regulations or rules, as well as provisions of the Supervisory Authority. Providing the data requested during registration is necessary to enable the use of services offered by the Portal: their absence, as well as partial or incorrect insertion could make it impossible for users to sign into the portal and then to use the services and the opportunities offered. WeAreStarting Srl It informs that users are free to give or not their consent to the processing, communication and reporting of personal data, which could even be detrimental and relating to information found by the Portal, for the purposes mentioned above, however WeAreStarting Srl has the obligation to inform you that your refusal to consent will make it impossible for the portal to deliver the services required. Location for data processing The processing of data collected is performed at the office of the company managing the Portal (shown in the "Data Controller") and are carried out only by technical personnel of the company or others charged with occasional maintenance. Databases and servers in which your personal data will be stored are stored on secure servers and databases located within the European Union. For safety reasons, the data backup will be made periodically. Type of processed data Browsing data IT systems and software procedures used to operate the Gateway website during their normal operation acquire some personal data whose transmission is implicit in the communication protocols of the Internet. This information is not collected to be associated with a user, but by their nature could, through processing and association with data held by third parties, allow to identify users. This category of data includes IP addresses or domain names of computers used by users connecting to the site, URI (Uniform Resource Identifier) of items selected, time of request, the method used to submit the requests to the server, the file size obtained in response, the numerical code indicating the status of response from the server (successful, error, etc.) and other parameters regarding the operating system and computer environment. These data are used only to obtain anonymous statistical information about the site and to check its correct functioning and are deleted immediately after processing. Data provided voluntarily by users The optional, explicit and voluntary insertion of addresses listed on the Portal involves the later acquisition of the sender's address in order to respond to requests, and any other data included in the message. Among the data collected, either independently or through third parties, there are: cookies, usage data, name, , username, phone number, occupation, province, state, country, zip code, gender, date of birth, city, address and picture. Other Personal Information collected may be listed in other sections of the information in question or by informative texts displayed together with the collection of the data. Personal data can be entered voluntarily by you, or collected automatically when using the portal. [2]

3 Registered issuers can enter the contents (such as documents, information, images, video, certificates, certificates, calculations, etc.) to make them available to the operators of the Portal; data of third parties may be used only if you have acquired the explicit prior consent of the parties concerned by the processing of such data and transmit them to third parties: broadcasters, therefore, take note that it is forbidden to enter, in the web space made available to them, sensitive and legal data (according to art. 4, par. 1, letters d) and e) of the Privacy Code of the Italian law) and contents depicting minors without the consent of the person exercising parental authority over them and, in any case, personal data to third parties without the necessary authorization to its online dissemination; the Issuer will assume, therefore, the responsibility of the content of all documents, images, and other files loaded, relieving WeAreStarting Srl and the companies that support the online accessibility about possible violations of the Privacy Code for any personal information and/or images to third parties contained therein. The User is responsible for the personal information of third parties published or shared through the portal and warrants that he/she has the right to communicate or broadcast them, freeing the Manager Portal from any liability to third parties. Any use of cookies (or other tracking tools) by the Portal, unless otherwise stated, aims to identify the User and register their preferences for purposes strictly related to the provision of the service you request same. WeAreStarting Srl, in order to perform more efficiently its services, may require from specialized companies and duly authorized, and make it available on information regarding issuers that are regularly registered on the portal and use the same information and in particular may request and publish records, documents and information stored in databases, that are subject to legal disclosure according to the law or advertising news and information integrated with data from public records and public archives, such data may be further enhanced by the integrated assessment carried out by companies authorized to develop own ratings containing specific public data, from the Chamber of Commerce and Registers, with the addition of other data always public and/or relating to the performance of economic activities (the "Information retrieved by WeAreStarting Srl ). Cookies For the portal of WeAreStarting Srl we use the so-called session cookies, which are stored on the user's computer for technical and functional requirements only, for the transmission of session identifiers required to enable a safe and efficient site. Session data is stored on the server used by WeAreStarting Srl and it is available only when you use a signed cookie. Checks of browser, IP and time are used to co-verify data session associated with the cookie. The session data is deleted after 24 minutes when the page is loaded again. In this way, sensitive data relating to the user are not stored permanently. To improve the functioning of the Portal, third-party applications that may use cookies are used. These cookies are are related to third parties and, on the basis of the data they contain, they can be viewed and managed exclusively by their owners. The use of such tools created by third parties is the best practice currently in use. We have no direct control over the contents of cookies that these tools generate. Please check the websites of these third parties and their privacy policy for more information about their cookies and how to manage them and check the configuration of your internet browser. To ensure greater transparency and convenience, the web addresses of different information and procedures for the management/opt-out of cookie are shown below. [3]

4 Facebook Information: Configuration: accedere alla sezione privacy del proprio account Facebook. Twitter Information: Configuration: Linkedin Information: Configuration: Google+ Information: Configuration: MixPanel Information: Opt-out: Procedure and logic of the process Personal data are processed by automated tools for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are taken to prevent data loss, illicit or incorrect and unauthorized access. The data processing is carried out using manual, computer or electronic devices to store, manage and transmit the data. The systems used by WeAreStarting Srl allow to prevent public and indiscriminate access to information loaded on the Portal and the information obtained by WeAreStarting Srl subordinating the vision and/or extraction to a special registration process on the portal and authentication. [4]

5 Categories of third parties to whom the data might be disclosed The data provided by visitors and customers may be disclosed for the purposes described above to: Companies responsible for revision and control; Employees, consultants and collaborators of WeAreStarting Srl, or to companies in the group of WeAreStarting Srl and/or its partners in the management of online portals for raising risk capital for innovative start-ups, even a social vocation; Issuers raising capital on in order to provide the services requested by users; Company providing services for the detection, archiving, storage and processing of data coming from documents or supports provided or created by the clients whose objective is massive operations related to payments, checks and other securities and financial instruments and tools for the collection and payment; Organizations that supply storage of documents relating to relations with customers; Banking companies and, more generally, management of payment and investment services; Companies performing surveys about the quality of services provided and the level of customer satisfaction. Rights of interested parties The subjects to whom personal data refer have the right to obtain at any time confirmation of the existence of such data and to know the content and origin, verify its accuracy or request its integration, updating, or rectification, erasure or blocking pursuant to art. 7 of the Decree. N. 196/2003 of the Italian law. Any request for the exercise of those rights, will be addressed by registered mail or by at info@wearestarting.it to the attention of the holder of the process. Changes to the information document for the processing of personal data This information document on the processing of personal data is subject to change and / or additions over time, therefore WeAreStarting Srl recommend checking periodically the information document on the processing of personal data. [5]