This Privacy Policy is meant to help you understand what information we collect and why we collect it.

Privacy Policy

INFORMATION - Art.13 EU Regulation 2016/679

Treasure Hunt in Italy are committed to protecting and safeguarding the privacy of the users of their site https://www.treasurehuntinitaly.com; in fact, our technology is constantly evolving to ensure adequate levels of privacy, security and transparency.

This information explains how our company, in synergy with its Partners, is committed to protecting the information collected for the use of our products and services: this information confirms Treasure Hunt in Italy commitment to be transparent towards the User about the data you collect, how you use them and how you share them.

The purpose of this document is to provide the interested party with the necessary information so that he can express, if he deems it appropriate, explicit and informed consent to the treatments carried out. We hope to explain it in a clear and understandable way, but we will provide the contact details below to contact us in case of questions.

In general, any information or personal data that will be provided to Treasure Hunt in Italy through the Site, or that is collected in another way in the use of the services offered by Treasure Hunt in Italy ("services"), as better defined below, will be treated according to internationally recognized principles of lawfulness, correctness, transparency, purpose limitation and conservation, data minimization, accuracy, integrity and confidentiality.

This information was drafted on 10 February 2019; occasionally we may need to change it, also due to changes in the applicable legislation. To stay updated, we invite the interested party to regularly visit this section to gain knowledge of the most recent and updated version of the Information, in any case every registered user will be regularly informed of the changes made.

By using our services, you consent to the use of your data by us pursuant to this Privacy Policy.

A necessary note: if the interested party does not agree with this Privacy Policy, it is necessary to stop using our services.

 

INDEX

 1. Data Controller and Data Protection Officer

 2. The data being processed

 2.a. Name, contacts and other personal data

 2.b. Data provided voluntarily by the interested party

 2.c. Third-party data provided by the interested party

 2.d. Navigation data

 2.e. Cookie

 3. Legal basis and mandatory or optional nature of the processing

 4. Purpose of the processing

 5. Recipients of personal data

 6. Transfers of personal data

 7. Treatment modalities

 8. Storage of personal data

 9. Social Media

 10. Rights of the interested party

 11. Changes

 12. Definitions

 

1. Data Controller and Data Protection Officer.

The data controller in relation to all personal data that is processed through the Site is SWD S.r.l.s., via Francesco Todaro, 3 - 98123 Messina, Italy - VAT ID: IT03441050832 ("Treasure Hunt in Italy" from now on), which can be contacted at the following address: rpd@treasurehuntinitaly.com.

The Data Protection Officer (DPO) can be contacted at the following address: rpd@treasurehuntinitaly.com.

 

2. The data being processed.

The personal data processed through the Site are the following:

a. Name, contact details and other personal data

In the sections of the "Contact Us" or "Request Information" section, you will be asked to enter information such as the name of the contact person, the company name, telephone number, address and e-mail address. Furthermore, whenever the interested party participates in events whose registration takes place through the Site or communicates with Treasure Hunt in Italy through the contacts found on the Site, Treasure Hunt in Italy may collect the additional information that the Data Subject decides to provide.

b. Nominations

By registering in the section of the Website concerning the applications in Treasure Hunt in Italy, at https://www.treasurehuntinitaly.com/contacts/work-with-us ("Work with us"), you will be asked to provide your personal data (such as Name, Surname, Date of Birth, Address, telephone), and some professional or work details (training, academic qualifications, professional qualifications and desired workplace). The personal data provided for this purpose will be processed by Treasure Hunt in Italy as described in the specific information provided there.

c. Third-party data provided by the interested party

As already mentioned above, in some parts of the site, it is allowed to insert text messages, visible to Treasure Hunt in Italy, which could contain (voluntarily or not) personal data of other people.

With respect to these hypotheses, the interested party must consider himself/herself as the data controller, assuming all the legal obligations and responsibilities towards the "interested third parties".

d. Navigation data

The computer systems and software procedures used to operate the Site acquire, by default, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category includes IP addresses, domain names of computers used by users who connect to the Site, addresses in URI (Uniform Resource Identifier) ​​notation, time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the IT environment of the interested party. This data is used only to obtain anonymous statistical information on the use of the Site, to check its correct functioning, to provide the User with targeted advertising (for a complete explanation of these forms of use, see the cookie policy ), and to identify anomalies and/or abuses. To collect information, in aggregate form, on the number of users and on how they visit the site, Treasure Hunt in Italy uses, among others, the Google Analytics service, whose cookie policy can be viewed at:

https://support.google.com/analytics/answer/6004245

and Google AdWords, whose Privacy policy is available at the following address:

https://policies.google.com/technologies/ads?hl=it&gl=it

e. Cookies

Information on the use of cookies is available in the page:

https://www.treasurehuntinitaly.com/privacy

 

3. Legal basis and mandatory or optional nature of the processing

The legal bases used by Treasure Hunt in Italy to process personal data, according to the purposes indicated in Article 4 below, are the following:

  • Service provision/fulfillment of contractual obligations: the processing for this purpose is necessary for the execution of the contract signed between Treasure Hunt in Italy and the interested party and, therefore, to be able to provide the contractually agreed services. The provision of personal data for this purpose is not mandatory, but in the absence of this it will not be possible to provide any Service.
  • Legitimate main interest of the owner: the treatment is necessary to make checks and assessments on the results and on the progress of the contractual relationship, as well as on the risks connected to it (such as: truthfulness of the data provided, solvency even in the course of reporting and correct use of product and services).
  • Legal obligations: processing for this purpose is necessary for Treasure Hunt in Italy to fulfill any legal obligations. The personal data conferred to Treasure Hunt in Italy, will be treated according to the applicable legislation, which could lead to their storage and communication to the Authorities in charge.
  • Promotional communications to its customers: the processing for this purpose is based on the legitimate interest of Treasure Hunt in Italy to transmit marketing communications regarding the integration of products and services already purchased by our customers or the promotion of similar products and services. The interested party may, at any time and free of charge, interrupt the receipt of these communications by writing to rpd@treasurehuntinitaly.com and without prejudice to the lawfulness of the processing in the period of validity of the same consent.
  • Legitimate main interest of the owner: the processing of our customers' data, in this case, is necessary to improve the efficiency of products and services offered by Treasure Hunt in Italy. To this end, Treasure Hunt in Italy will be able to transmit questionnaires regarding the level of satisfaction and market surveys, make telephone calls or chat sessions; these questionnaires/market surveys in general will be designed to minimize the use of personal data.
  • Marketing: processing for this purpose is based solely on the consent of the interested party, which can be revoked at any time; The interested party may, at any time and free of charge, interrupt the receipt of these communications by writing to rpd@treasurehuntinitaly.com and without prejudice to the lawfulness of the processing in the period of validity of the same consent. In the event of revocation, Treasure Hunt in Italy will not proceed with any further communication.
 

4. Purpose of the processing

Treasure Hunt in Italy will process the personal data provided by Users only in the ways established in this Privacy Statement and in compliance with the laws in force. Personal data collected through the Site will be used for the following purposes:

  1. Supply of the service/fulfillment of contractual obligations: for purposes concerning the execution of the obligations envisaged by the General Contract Conditions (www.treasurehuntinitaly.com/contracts).
  2. Legitimate main interest of the owner: for verifications and assessments on the results and on the progress of the relationship, as well as on the risks connected to it (such as: truthfulness of the data provided, solvency even during the relationship), to draw up statistics, in anonymous form, on services rendered and about access to sites and commercial information and participation in fairs, events, seminars and any other initiative aimed at promoting Treasure Hunt in Italy products and services; to prevent or detect any abuse of the Site or any fraudulent activity; to improve the quality of services rendered, by sending questionnaires, feedback on participation in events, recording of calls and chats.
  3. Legal obligations to which the data controller is subject: for the fulfillment of the law and / or provisions of public bodies, which impose on Treasure Hunt in Italy the collection and/or further processing of certain types of personal data.
  4. Sending promotional offers to its customers: to send, via e-mail, SMS, by telephone, via banner, instant messaging, through an operator, via paper mail and through the official Treasure Hunt in Italy social pages (RSS, Twitter, Facebook, LinkedIn and YouTube), marketing communications, promotions and personalized content, providing targeted advertising, concerning products and services similar to those that the Customer has already purchased.
  5. Marketing: to send marketing communications, promotions and advertising to anyone who has previously expressed their consent, via e-mail, SMS, telephone, banner, instant messaging, through an operator, via paper mail and through social pages Treasure Hunt in Italy officers (RSS, Twitter, Facebook, LinkedIn and YouTube), relating to the products and services of Systems and third parties.

In the cases referred to in points a), b), c), d) of this article, Treasure Hunt in Italy is authorized to process personal data in accordance with the applicable data protection rules, without the need to collect a specific consent from the 'Interested. The processing for the purposes referred to in points a), b) and c) is necessary in order to provide the services and, therefore, for the execution of the contract itself. The provision of Data to Treasure Hunt in Italy for this purpose is not mandatory, but otherwise no Service will be provided.

In relation to the purposes referred to in point d) the interested party may object to their processing at any time and free of charge: in the event of revocation, the interested party may not use the services specified above.

In the cases referred to in the previous point e) of the present article, Treasure Hunt in Italy will treat the data only after obtaining the consent from the Interested party. The granting of consent, as better specified in the previous art. 3 "Legal basis and mandatory or optional nature of the processing", is not mandatory, and where provided, the interested party is free to revoke it at any time without any consequence (except that of not being able to receive marketing communications). More information on the withdrawal of consent previously given is provided in Article 10 of this Notice.

 

5. Recipients of personal data

The personal data of the interested party may be destined to the subjects indicated below ("Recipients"):

  • Subjects that act as Partners: we work with our Partners throughout the Italian territory, who distribute or promote our products and services. This means that, according to defined criteria, these Partners have been enabled to view some lists of personal data necessary to render the service or to inform the interested party about the initiatives of Treasure Hunt in Italy; the names and contacts of these subjects are available by sending a specific request to the email address: rpd@treasurehuntinitaly.com
  • Subjects that typically act as data controllers, that is: individuals, companies or professional offices that provide assistance and consultancy services to Treasure Hunt in Italy in accounting, administrative, legal, tax, financial, debt collection related to the provision of Services, mailing of advertising material or contractual communications, companies organizing training events, subjects providing services for web meetings and training web seminars; a complete list of all those responsible can be requested by contacting the email address: rpd@treasurehuntinitaly.com
  • Subjects providing e-mail services (platforms for sending e-mails), delegated to also manage requests for cancellation submitted by users for processing purposes referred to in point 4, letters (d, (e;
  • Subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks);
  • Persons authorized by Treasure Hunt in Italy to process personal data necessary to carry out activities strictly related to the supply of products/services; a legal obligation of confidentiality applies to these persons;
  • Associated companies of the Group for administrative purposes;
  • Factoring companies, credit institutions, debt collection companies, credit insurance companies;
  • Professional orders or Training Institutions accredited with these Orders;
  • Competent subjects, bodies or Authorities to which it is mandatory to communicate personal data to fulfill legal obligations, to prevent abuse or fraud.
 

6. Transfers of personal data

For purposes related to the execution of the contract, some data could be communicated to recipients located outside the EU Economic Area.

Systems ensures that the processing of personal data by these recipients takes place in compliance with the applicable legislation.

Indeed, transfers are made through adequate guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate.

More information is available from Treasure Hunt in Italy by writing to the following address: rpd@treasurehuntinitaly.com

The subjects to whom the data will be communicated will be appointed as Data Processors.

A complete list of the Managers can be requested by contacting the e-mail address: rpd@treasurehuntinitaly.com

 

7. Treatment modalities

The processing of personal data is carried out by means of the following operations: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.

Personal data is processed both on paper and electronic and/or automated, using a cloud-hosted website managed by our company and located in Italy.

The data will be processed in such a way as to guarantee continuous security and confidentiality.

In compliance with European regulations and national laws on data protection, Treasure Hunt in Italy has put in place specific procedures to prevent unauthorized access to data, their improper or illegal use, as well as to prevent destruction or even accidental loss of the data itself.

Only authorized personnel can access the data during the course of their work.

 

8. Storage of personal data

The personal data processed for the purpose of "Service Delivery/Contractual Fulfillment" will be kept for the time strictly necessary to achieve the aforementioned purpose. In any case, since these personal data are processed to provide the products/services, Treasure Hunt in Italy may keep them for a longer period, in particular as may be necessary in order to protect the interests of Treasure Hunt in Italy from possible responsibilities related to the supply.

Personal data processed for marketing purposes will be kept by Treasure Hunt in Italy until the consent given by the interested party is revoked. Once the consent has been revoked, the use of the data for these purposes will cease, but may preserve them in order to protect the interests of Treasure Hunt in Italy from possible responsibilities based on such treatments.

Personal data processed for the purpose of sending promotional offers to customers will be kept by Treasure Hunt in Italy until the interested party objects to the processing by writing to rpd@treasurehuntinitaly.com

The personal data processed for the purpose of fulfilling legal obligations will be kept by Treasure Hunt in Italy for the period provided for by specific legal obligations or by the applicable legislation.

The personal data processed to prevent abuse/fraud will be kept by Treasure Hunt in Italy for the time strictly necessary for the aforementioned purpose.

 

9. Social Media

Treasure Hunt in Italy uses social media for the purpose of communicating content relating to its products and services.

https://twitter.com/treasurehuntinitaly

https://www.facebook.com/treasurehuntinitaly

https://www.linkedin.com/treasurehuntinitaly

The sites of third parties which can be accessed through this website are not covered by this information.

To consult the privacy policies of these social media, please visit the pages:

TWITTER: https://twitter.com/en/privacy

FACEBOOK: https://en-en.facebook.com/policy.php

LINKEDIN: https://www.linkedin.com/legal/privacy-policy?_l=en_EN

YOUTUBE: https://policies.google.com/privacy?hl=en&gl=en

 

We use the Tawk.to chat platform provided and run by Tawk.to Ltd, a EU company based in London and the offices of which are located in Latvia. The use of the Tawk.to chat is subject to the legal terms and conditions and privacy policy available on their website:

https://www.tawk.to/terms-of-service/

https://www.tawk.to/privacy-policy/

You hereby agree and acknowledge that Treasure Hunt in Italy has nothing to do with the functioning of the platform and the treatment procedures implemented by Tawk.to with regard to the data provided by you while using the platform. Furthermore, you hereby agree to your data running through the servers used by the above mentioned company. Such data will be processed by us in order to deal with your requests and answer your suggestions or complaints, as well as to improve the quality of our Website and our services.

 

10. Rights of the interested party

The interested party has the right to ask Treasure Hunt in Italy at any time:

  • Access to their personal data, (and/or a copy of such personal data), as well as further information on the treatments in progress on them;
  • Correction or updating of personal data;
  • The cancellation of personal data from the Treasure Hunt in Italy databases;
  • The limitation of the processing of personal data by Treasure Hunt in Italy;
  • Data portability, that is to obtain in a structured format, commonly used and readable by an automatic device, a copy of your personal data provided to Treasure Hunt in Italy, or to request its transmission to another Owner;
  • Opposition to the processing of personal data;
  • Revocation of your consent for the intended purposes.

Treasure Hunt in Italy will provide the interested party with information relating to one or more of the actions taken as per the previous list without undue delay and, in any case, at the latest within one month of the request itself.

This deadline may be extended by two months, taking into account the complexity and the number of requests, with consequent information to the interested party of this extension and the reasons for the delay, to be provided within one month of receipt of the request.

The interested party also has the right to lodge a complaint with the competent Control Authority (for Italy, Privacy Guarantor, http://www.garanteprivacy.it), if he considers that the processing of his personal data is contrary to the legislation in force .

The exercise of the rights referred to in this article may be exercised by the interested party at the following email address: rpd@treasurehuntinitaly.com.

 

11. Changes

This Notice is effective as of May 22, 2019 Treasure Hunt in Italy reserves the right to modify or update it also due to possible regulatory changes or practices coming from the National Control Authority or from the European Data Protection Committee.

 

12. Definitions

1) Personal information: any information concerning an identified or identifiable natural person (Interested); the identifiable natural person who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychic, economic, cultural or social;

2) Treatment: any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as the collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of provision, comparison or interconnection, limitation, cancellation or destruction;

3) Data controller: the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria applicable to his designation may be established by Union or Member State law;

4) Data Processor: the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller;

5) Recipient: the natural or legal person, the public authority, the service or another body that receives communication of personal data, whether or not they are third parties. However, public authorities that can receive communication of personal data in the context of a specific investigation in accordance with Union or Member State law are not considered as recipients; the processing of such data by said public authorities is in compliance with the applicable data protection laws according to the purposes of the processing;

6) Third: the natural or legal person, the public authority, the service or other body that is not the interested party, the data controller, the data processor and the persons authorized to process personal data under the direct authority of the data controller or Responsible;

7) Consent of the interested party: any manifestation of free, specific, informed and unequivocal will of the Interested party, with which the same expresses his/her own assent, through unequivocal positive declaration or action, that the personal data concerning him/her are treated;

8) Violation of personal data: the security breach that accidentally or illegally involves the destruction, loss, modification, unauthorized disclosure or access to personal data transmitted, stored or otherwise processed;

9) Binding company rules: the policies regarding the protection of personal data applied by a data controller or Data Processor established in the territory of a Member State to the transfer or transfer of personal data to a controller or data processor in one or more countries third parties, in the context of an entrepreneurial group or group of companies which carries out a common economic activity;

10) Supervisory authority: the independent public authority established by a Member State pursuant to Article 51;

11) Control authority concerned: a Control Authority concerned with the processing of personal data as:

  • the data controller or data processor is established in the territory of the Member State of this supervisory authority;
  • the data subjects who reside in the Member State of the Control Authority are or are probably substantially influenced by the treatment; or
  • a complaint has been proposed to this supervisory authority.

12) Cross-border treatment: a) processing of personal data that takes place in the context of the activities of establishments in more than one Member State of a data controller or Data Processor in the Union where the data controller or data processor is established in more than one Member State; or

b) processing of personal data that takes place in the context of the activities of a single establishment of a data controller or Data Processor in the Union, but which affects or probably substantially affects interested parties in more than one Member State.

13) Partners: the subject to whom Treasure Hunt in Italy, on the basis of a signed contract, confers the quality and assignment of Treasure Hunt in Italy Dealer, and as such authorized for the distribution, installation and assistance of Treasure Hunt in Italy products.