Privacy

PRIVACY POLICY

Introduction

The protection of privacy and the legitimate use of personal data are a priority for GlareStars  (“we” or “GlareStars”). We are committed to ensuring your privacy. This Privacy Policy (“Policy”) explains how we collect, use, store and disclose your personal data, in the context of providing services (collectively, the “Services”;). GlareStars reserves the right to periodically modify this Policy, in particular if the modifications are due to changes in our operating methods, or to legislative or regulatory changes. For the purposes of European Union data protection laws, in particular the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament) GlareStars is the data controller of your personal data. You can contact us by sending an email to info@glarestars.com or by post, sending your request to the GlareStars offices.

Data Controller of your personal data

The data controller is GlareStars with headquarters in Via Alessandro Volta 8, 31056 – Roncade, TV – Italy, VAT number 03676100260, Email info@glarestars.com

Purpose of the processing of your personal data

The processing of your personal data is aimed at fulfilling contractual and commercial obligations, as well as fiscal and accounting and any other regulatory obligations. Your personal data may be processed in paper form and/or in accordance with the purposes indicated above.

Legal basis for the processing of your personal data

GlareStars processes your personal data based on express consent; Your express consent will be requested separately for all possible cases of processing based on consent in accordance with the art. 6 c.1 GDPR and, by way of example, for all cases in which the transfer of your personal data to countries not belonging to the European Union is necessary, with the exception of cases in which the transfer is authorized on the basis of specific decisions of the European Union and the Guarantor for the protection of personal data, such as decision 1250/2016, for which no further consent is required.

Failure to communicate your personal data

Failure to communicate your personal data prevents the establishment of the contractual relationship of which you are a party and the fulfillment of regulatory obligations, including accounting and tax ones.

Storage times of your personal data

Your personal data, subject to processing for the purposes indicated above, will be kept for the duration of the contract and, subsequently, for the time in which the Data Controller is subject to conservation obligations for tax purposes or other purposes, required by law or regulation. Upon expiry, your data will be deleted or anonymized.

Sharing of your personal data with third parties

We may share your personal data with external suppliers for the sole purpose of providing you with the requested Services. Unless we inform you otherwise, and you are asked for your consent to transfer the data to another data controller, each of these third parties acts as data controller on our instructions, and has signed an appointment agreement of the data controller with us pursuant to art. 28 GDPR. Among them, there are:

• provider of cloud hosting and server maintenance services,

• IT companies providing software or similar services,

• suppliers of telephone, video or digital communication tools,

• consultants, agents, lawyers, and professionals appointed by GlareStars,

• external accountants, auditors or advisors,

• payment service providers, banks, credit reference and fraud prevention agencies, and insurance companies,

• subjects who process data in compliance with specific legal obligations,

• Judicial or administrative authorities, for the fulfillment of legal obligations.

Some of the aforementioned third parties may be based outside the European Union. In this case, it is our obligation to ensure that the legal requirements exist to proceed with the transfer of your data in complete safety, and we will in any case remain responsible for compliance with your rights and legal obligations in relation to the personal data transferred.

Finally, we may disclose your data to comply with any requirements or dictates of law or regulation, to enforce compliance with our policies or conditions of use or the Service Agreement, to contact judicial authorities or other public authorities or to comply with their legitimate requests, or to protect our rights. Except as mentioned above, we will not transfer your personal information to third parties without your consent.

What are your rights regarding the processing of personal data

Under the GDPR you have the following rights:

• you have the right to be informed about the processing of your personal data (i.e. for what purposes, what type of personal data, to which recipients it is communicated, retention periods, any third-party sources from which it was obtained, verification of automated decisions, including profiling, the logic used, as well as the significance and expected consequences). This Information, as well as (where applicable) the order conditions of the services or any other information or notifications relating to the processing of your personal data made available by GlareStars, fulfill your right to be informed;

• ask us for a copy of the personal data we process about you; or to delete (if you believe we are not entitled to retain it) or to rectify (if you believe it is inaccurate) your personal data;

• object to, and therefore limit, our processing of your data (in which case, you will only have access to those features of the Services that do not require the type of processing to which you have objected);

• revoke any consent to data processing previously given by you (the revocation of consent does not invalidate the legitimacy of the processing carried out before the revocation itself, or on the basis of legal assumptions other than consent);

• request the “portability” of your data stored by us in digital format (i.e. to receive the personal data concerning you in a structured, commonly used and machine-readable format in order to transfer them to another data controller, or to obtain such transfer directly, if this is technically feasible), by contacting us preferably in the manner indicated in the “Contacts” section of this Policy;

• you have the right to lodge a complaint by contacting us in the manner indicated in the “Contacts” section of this Policy or, if your complaint is not resolved satisfactorily by us, by contacting the Guarantor Authority for the Protection of Personal Data (reachable through the website www.garanteprivacy.it/) if you believe that we are processing your personal data in a manner contrary to the law;

We will always comply with our legal obligations regarding your rights as a data subject, to enable you to exercise them fully. We will try to respond to you within a reasonable time and, in any case, within one month (or in the times that we will communicate to you immediately in the case of complex or numerous requests). We reserve the right to charge a reasonable fee (which reflects the costs of providing the information) or to refuse to respond when requests are manifestly unfounded or excessive: in this case, we will explain the situation to you and let you know your rights. We also reserve the right to verify the identity of the applicant, to avoid sharing your personal data with unauthorized third parties. Our goal is to ensure that the information we hold about you is accurate at all times. To help us keep your information up to date, you should take care to inform us of any changes to your personal data. Following a report or request from you, we will make every effort to ensure that the personal data in our possession is accurate and updated.

Automated decisions and profiling

We do not resort to processing of personal data that results in decisions based entirely and solely on the automated processing of your personal data. We do not use any profiling system or tool to process your data, nor fully automated decision-making processes based on your personal data.

How we protect your data

GlareStars adopts technical, physical, electronic, operational and administrative security measures, adequate to protect your personal data from unauthorized access. We follow industry-accepted standards to protect the personal information you provide to us, both during transmission and after we receive it.

Contacts

For any questions relating to your personal data, you can contact us:

• via e-mail to: info@glarestars.com
• by post to the address of our registered office: Via Alessandro Volta 8, 31056 Roncade, TV – Italy