For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the “GDPR”), the site will be the data controller responsible for any personal data we process.
We may share your information with third parties (data processor) acting on behalf of the writer in accordance with the art. 28 of the Regulation, as well as authorized and educated persons on the handling of personal data processing pursuant to art. 29 of the Regulation, in compliance with what is indicated in this policy. The following types of third parties may be involved in the processing of data:
- third party software providers and technical support providers;
- professional advisers such as accountants, tax advisors, auditors, and insurance brokers;
- service providers that assist us in providing our services;
- our advertising and promotional agencies carrying out our marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you.
Purpose of the processing
TINKOIN processes the personal data of individuals, legal entities, sole proprietorships and/or freelancers (the “Interested Parties”) for the following purposes:
- To provide assistance and information requested by you through the contacts provided on the site. Providing such data is optional and may involve sending e-mail messages to the e-mail addresses indicated on this site by you. The sender’s e-mail address will then be acquired, necessary to respond to requests, as well as any other personal data included in the communication. The processing is based on the execution of a contract and pre-contractual measures.
- Need to execute a contract of which the interested party is a part or to carry out pre-contractual activities at your request. This need is the legal basis that legitimates the resulting treatments. The provision of the necessary data for these purposes represents, depending on the case, a contractual obligation or a necessary requirement for the conclusion of the contract; failing that, TINKOIN would be unable to establish the relationship or execute it.
- Need to comply with legal obligations (i.e. obligations under anti-money laundering legislation, provisions issued by the Supervisory Authority, the Judiciary Authority, etc.). This need is the legal basis that legitimates the resulting treatments. Providing the necessary data for these purposes is a legal obligation; in the absence of them, TINKOIN would be unable to establish relations and could have the obligation to make reports.
- To perform, with your consent, direct marketing activities, such as: analysis on consumption habits; carry out market research in order to improve our commercial offer; send you promotions and invitations suitable for you and your preferences through electronic communications, telephone and/or traditional mail; social, cultural and solidarity initiatives. The legal basis for such processing is your consent.
We will retain your information as long as is needed to fulfill our legal or regulatory obligations. The period of storage of personal data depends on the purpose for which they are processed, and it is not possible to indicate the retention period in a reasonably understandable manner in this statement. The criteria used to determine the applicable retention period are: we will retain the personal data covered by this information for the time (s) necessary for the purpose, (ii) necessary for the performance of the business relationship with the user, (iii) accepted by the user and / or (iv) required by applicable laws.
Types of information we obtain
Non-personal information: When you visit Tinkoin.com our system obtains information regarding your use of our Website through automated means, including, but not limited to, web server logs, your IP address and unique mobile device identification numbers, data for advertising and analytics purposes, preferences regarding online marketing and other data you choose to give us.
Data provided by the user: possible data provided by the user through the “Contact” service or the optional and spontaneous sending of messages, by e-mail or traditional, to the TINKOIN addresses indicated on the site. In the event that you should communicate particular data to us in the communications (for example medical data, on sexual orientation, inherent to political, religious opinions, etc. – reference to article 9 of Reg.UE 2016/679 -) , TINKOIN will find itself having to process and collect data for which the law requires your consent. In such cases we inform you that the Data will be processed exclusively to respond to requests received by TINKOIN.
We do not intend to solicit or collect Personal Information from anyone under the age of 18. If you are under 18 or are not of a legal age of your country, you shall not provide Personal Information on this Site.
Transfer of personal data
Data processing will be performed exclusively in a Member State of the European Union (EU) or in a Member State of the European Economic Area (EEA).
TINKOIN has as its objective the protection of the personal data supplied to it, basing its treatment on the principles of correctness, lawfulness, and transparency. We, therefore, inform you that your data will be processed through the use of appropriate tools and procedures to guarantee maximum security and confidentiality, through archives and paper supports, with the aid of digital media, computerized and telematic means. Communications may take place in traditional ways (eg paper mail, telephone), automated and similar (eg fax, e-mail, etc.).
Personal data is processed for the time strictly necessary to achieve the purposes for which it was collected. Specific security measures are observed to prevent the loss of data, illicit or incorrect use and unauthorized access. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.
In relation to the processing of data, in accordance with the provisions of Chapter III of the Regulation, the data subject is entitled to request access to personal data, rectify any personal data, integration or deletion of the data or restrict the processing which they concern him or to oppose the treatment, as well as to propose a complaint to a control authority. Based on the right to portability, in the case in which the treatment is based on the contract or on the consent and is carried out with automated instruments, the interested party has the right to receive the data in a structured format, commonly used and readable by an automatic device, and, if technically feasible, to transmit them to another holder without impediment.
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