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Via Panciatichi 38/2 - 50127 Firenze

UPmedia Privacy Policy

Pursuant to EU Regulation 2016/679 (GDPR) and Legislative Decree 196/03 (and subsequent amendments)

Last modified: December 22, 2021
UPmedia Srl (hereinafter UPmedia) is committed to protecting your privacy. This Policy describes the types of data we may collect and process through your use of the following websites:

• https://www.upmediagroup.it

• https://kioskmode.it/

• https://www.parrotassistant.it/

and other web pages managed by UPmedia, describing their collection, use, maintenance, protection and disclosure practices. By using the Website and the services offered through it, the data subject consents to the processing practices described in this Privacy Policy. If for some reason you do not agree with the following, please do not use the services offered.

Definitions

Data Controller: the natural person, the legal person, the public administration and any other body, association or body to which they are responsible, even together with another owner, for decisions regarding the purposes, methods of processing personal data and the tools used, including the information security profile.

Data processor: the person, the company, the body, the association or the body to which the owner entrusts, also externally, for the particular experience or ability, tasks of management and control of the data processing.

End-User or Interested: these terms refer to anyone who browses through one of the web pages managed by UPmedia, is a customer, or potential one, of UPmedia (having purchased the products and services offered directly or through an authorized partner) uses an APP managed by UPmedia , is contacted or enters data through the website www.upmediagroup.it. In the case of minors, the provisions indicated in Art. 2-quinquies of Legislative Decree 196/03 (with the changes made by Legislative Decree 101/18).

ChatBot: chat bot, chatbot or chatterbot, is software designed to simulate a conversation with a human being and is used for various purposes such as online help, to answer FAQs of users accessing a site etc.; within its web spaces, the Owner could offer the possibility for end-users and customers to interact with a chatbot to offer the services requested by the end-user, improve the user experience with the disclosure of information (description of services, products, promotions, etc.) and to acquire contact information. In addition to a "virtual" assistant, the Data Controller also provides for human interaction between the interested parties and those in charge of UPmedia, through the use of the chat function, present on the web pages.
Apri in Google Traduttore

Web sites: the sites or web pages managed by the Owner such as www.upmediagroup.it.

Personal data: we consider personal any information that you voluntarily submit that personally identifies someone, including contact information, such as your name, email address, address, phone number, and other information about you or your business. Personal Information may also include information about any transaction, whether free or paid, information that is available on the Internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information. When the end user registers or logs in through one of his social channels, based on the configurations of his social accounts, some data is shared with www.upmediagroup.it and therefore with UPmedia. In addition, we also consider credit or debit card numbers, personal financial account information, passport numbers or other identification document numbers to be particularly important to you.

Details: Also known as "sensitive" data, we consider particular data to include racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, information relating to health, orientation and sex life, as well as biometric data and genetics

Navigation information: Refers to the information present on your computer and to visits to this website (and other web pages managed by UPMEDIA) such as the IP address, geographical location, browser type, reference source, duration of the visit and the pages viewed.

Consent: This refers to the free expression of will of the interested party with which he expressly accepts a specific treatment of his personal/sensitive data, of which he has been informed in advance by the Data Controller.

Data controller

UPmedia Srl with registered office in Via Panciatichi 38/2 - 50127 Florence (FI) – PI and CF 06990150481 – email contact privacy@upmediagroup.it, (hereinafter also referred to as, "UPMEDIA", or the "Owner"), which operates in the digital marketing sector also with the Kiosk Mode and Parrot Assistant brands, in the person of its legal representative, guarantees compliance with the regulations on the protection of personal data by providing the following information regarding the processing of data communicated or otherwise collected in the course of use of the site www.upmediagroup.it (the "platform" or "the site").

The Data Protection Officer (so-called DPO) appointed by UPMEDIA is: Findata Srl with registered office in Via Margherite n.39 Pollena T. (NA) in the person of Dr. Cino Wang Platania who replies to the following email address: DPO@upmediagroup.it

Personal data collected

3.1 Navigation data

The processing of personal data of users who visit and consult the Site is limited to the so-called navigation data whose transmission is necessary for the functioning of the computer systems and programs necessary for the operation of the Site but which by their very nature could, in association with other data, allow the identification of users. These include IP addresses or the names of the computers used by users connecting to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in the response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the IT platform used by the user. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning. These data may also be used to ascertain responsibility in the event of commission of computer crimes against the Site in accordance with the procedures in force at the competent Authorities. Except for this eventuality, navigation data is only stored temporarily in compliance with applicable legislation.

3.2 Data provided voluntarily by the user

Your contact and account details. UPmedia will keep the information you provide us (for example, personal and contact data) when you buy a product and/or service, interact with the after-sales assistance service or ask to be contacted for more information. Your payment details and billing. UPmedia will store the payment and billing information you provide us (for example, personal and contact details) when you purchase a product, for the purpose of managing your purchase orders and shipping products. Third party data provided directly by you. Any indication of personal data and contact details of any third party other than yourself represents a processing of personal data with respect to which you place yourself as independent data controller, assuming all the obligations and responsibilities established by current legislation on personal data. In this sense, you guarantee UPmedia that any data of third parties that will be indicated by you has been acquired by you in full compliance with current legislation on personal data and that there is an appropriate legal basis which legitimizes the communication of said personal data of third parties to UPmedia, indemnifying the latter from any dispute, claim, request for compensation for damages that should reach UPmedia from any interested third party deriving from the aforesaid communication.

3.3 Data provided with the use of the chatbot

The Chat bot, chatbot or chatterbot, is software designed to simulate a conversation with a human being. The main purpose of this software is to simulate human behavior and it is used for various purposes such as online help, answering FAQs of users accessing a site etc. Within its web spaces, UPmedia offers the possibility for end-users and customers to interact with a chatbot for the purpose of executing the existing contract or to improve the browsing experience and/or to request pre- contractual. Further information on data processing with this platform is available on the data processing information of the service itself.

3.4 Cookies

UPmedia, in order to protect visitors to its web pages, makes use of a third party (cookiebot) in order to guarantee the correct management, pursuant to the law, of consent relating to cookies. Below, the interested party will find the details about the cookies used and the relative indications for modifying the consents provided. In any case, the Data Controller remains available to provide any further information in this regard. Finally, with regard to mobile terminals, please consult the following web page, and search for the model of your device: http://www.allaboutcookies.org/[cookie_declaration]

Legal basis, purpose and nature of the processing
The following table illustrates the legal basis and the reasons why your data may be processed by UPmedia.

For the treatments referred to in points a), b) and c) referred to in the previous paragraph, the provision of data is necessary to allow you to create an account on the site, make purchases in the Shop and receive the other services on the site.
For the purposes d) and e), the provision of data is optional, any refusal will not cause any prejudice for the purposes from a) to c). The interested party may revoke his consent at any time, but this will in no way affect the processing carried out by UPmedia prior to such revocation.

Recipients of personal data

The user's personal data may be shared, for the purposes referred to in paragraph 3 of this Privacy Policy, with:

• individuals who act as Data Processors such as, by way of example: individuals, companies or professional firms that provide assistance and advice to UPmedia in accounting, administrative, legal, tax and financial matters;

• subjects delegated to carry out services of a technical nature; credit institutions and insurance companies. Both the forms on the site and the chatbot transfer personal data to the SMS Hosting platform which has been appointed as the external data processor;

• persons authorized by UPmedia to process personal data for activities strictly related to the provision of services, who have an adequate legal obligation of confidentiality;

• police forces, armed forces and other public administrations in order to fulfill the obligations established by laws, regulations and national or European legislation as well as to agencies or professionals for credit collection (e.g. outstanding debts towards us) or to allow the legal defense of UPmedia, for example in the event of network violations by users;

• only with the user's specific consent, personal data may be communicated to commercial partners of UPmedia or to third parties (subject to the adoption of security and data protection criteria by them in line with current legislation) for purposes of marketing and profiling as described above.

Storage period

The data collected will be kept for a period of time not exceeding the achievement of the purposes for which they are processed ("conservation limitation principle", art.5, GDPR) or on the basis of the deadlines set by law. The verification of the obsolescence of the data stored in relation to the purposes for which they were collected is carried out every 48 months.

Rights of the interested parties

The users to whom the personal data, possibly collected, refer have the right at any time to obtain confirmation of the existence or otherwise of the same data and to know its content and origin, verify its accuracy or request its integration or update, or rectification, cancellation, portability and limitation of processing pursuant to articles 15 and following, of the GDPR. The aforementioned rights can be exercised by sending a written communication to UPmedia Srl, Via Panciatichi 38/2 - 50127 Florence (FI), by sending an email to the email address: privacy@upmediagroup.it
The interested party has the right to lodge a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulation, if you believe that the processing of your personal data is contrary to the legislation in force.

Data transfer abroad

The data will be processed and stored in UPmedia's offices and IT systems.

Personal data may also be communicated, also to let you interact with the customer assistance service, to companies that provide services - specifically appointed as data controllers pursuant to art. 28 GDPR - which are based in countries that do not belong to the European Union and, in particular, in the United States of America. These data transfers are alternatively authorized on the basis:

• an adequacy decision of the third country to which the data are transferred, adopted by the European Commission pursuant to art. 45 of the GDPR; or

• the appropriate or opportune guarantees provided for by articles 46, 47 and 49 of the GDPR (such as the standard contractual clauses approved by the European Commission, the binding corporate rules, the guarantees of a contractual or contractual nature provided by the data controllers involved, or such as the exceptions to the prohibition of transfer applicable in specific situations), as well as on the basis of the right to contact the Data Controller to obtain the contact details of the subjects to whom the personal data are communicated, from whom it is possible to receive indications on the means to obtain a copy of the data processed or on the place where the data has been made available.

Data security details

Personal data is protected by technical, IT, organisational, logistical and procedural security measures, against the risks of destruction or loss, even accidental, and of unauthorized access or unauthorized processing. These measures are periodically updated on the basis of technical progress, the nature of the data and the specific characteristics of the treatment, constantly monitored and verified over time. These security measures correspond to the requirements that the Data Controller and the managers appointed by him have identified as adequate. Periodic "risk analysis" activities are conducted to verify adherence to the security protocols adopted and new security measures are introduced or updated, if necessary, following organizational changes and technological innovations or changes in the type of data collected. The security measures are constantly monitored and periodically verified.

Changes

The Owner reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. We therefore invite you to visit this section regularly to read the most recent and updated version of this information so as to always be updated on the data collected and on the use made of it by UPmedia.

Information on Social Networks and Google

Below we provide you with some information regarding UPmedia's use of Google and other Social Media.

11.1. Joint ownership of statistical data processing with Facebook

For “Pages,” Facebook offers the “Insights” tool, a feature that provides aggregated data that helps you understand how people interact with Facebook Pages.

With regard to the Facebook page https://www.facebook.com/upmediaagency/, UPmedia is Joint Controller of the processing of statistical data jointly with Facebook Ireland Limited ("Facebook Ireland").

At this link (https://www.facebook.com/legal/terms/page_controller_addendum) it is possible to consult the appendix on the ownership of the treatment for Insights of the Facebook Page, which indicates the division of responsibilities of Facebook Ireland and UPmedia as as administrator of the page https://www.facebook.com/upmediaagency/.

Facebook provides the following information in detail:

• What types of information Facebook collects
• How Facebook uses this information
• How this information is shared
• The legal bases for data processing
• How to exercise the rights provided by the GDPR
• Facebook Ireland contact details for data protection matters
• The contact details of the Data Protection Officer for Facebook Ireland
• The rights of the Facebook visitor under the GDPR
• The data retention period
• Management of Facebook cookies.

11.2. Instagram

UPmedia manages the Instagram account reachable at https://www.instagram.com/up_media_agency/

On this page (https://help.instagram.com/519522125107875) you can consult the privacy policy of Instagram.

On this page (https://help.instagram.com/1896641480634370?ref=ig) you can consult the Instagram cookie information.

11.3 LinkedIn

UPmedia manages the LinkedIn page which can be reached at the address https://www.linkedin.com/company/upmedia-group

On this page (https://privacy.linkedin.com/it-it/gdpr) you can consult LinkedIn's privacy policy.

On this page (https://www.linkedin.com/legal/cookie-policy) you can consult the LinkedIn cookie policy.

11.4 Google Analytics with anonymized IP (Google Inc.)
Google Analytics is a web analytics service provided by Google LLC or by Google Ireland Limited, depending on the location this website is accessed from ("Google"). Google uses the personal data collected for the purpose of tracking and examining the use of this site, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the ads of its advertising network.
This integration of Google Analytics makes your IP address anonymous. The anonymization works by shortening the IP address of the Users within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area.

Personal Data collected: Cookies; Usage data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

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Via Panciatichi 38/2 - 50127 Firenze

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