PRIVACY POLICY

In this section, in accordance with the European legislation introduced by EU Regulation 679/2016 and the Italian legislation (Legislative Decree no. 196/2003), information is provided on the processing of personal data of Users consulting the pages of the website www.licensel.com (hereinafter: “Website”) or using the purchasing services made available on the same (hereinafter: “Users” or “Interested Parties”).

This information is provided solely for the Site and not for any other websites that may be consulted by the user via links within the Site.

Data controller

The data controller of the personal data of users of the www.licensel.com is Digicode Solution LLP (from now on also “Company“), Partnership No. OC454045, established in London, 5th Floor, 22 Eastcheap, EC3M 1EU. Email address: [email protected].

E-mail to contact the owner and request deletion of your data, if collected, with your consent: [email protected].

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A – Type of data processed

1. Identifying data

In accordance with the European legislation introduced by EU Regulation 679/2016, consultation of the Site and the possible purchase of products sold on the Site may entail the processing of data capable of directly or indirectly identifying a natural person such as: name, surname, residential address, e-mail address, telephone number, IP address.

The Site does not require the Data Subject to provide any so-called ‘special’ data, i.e., in accordance with the GDPR (art. 9), personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to a person’s health or sexual life or sexual orientation. In the event that the requested service requires the processing of such data, the data subject will be informed in advance and asked to give explicit consent.

1. Bank data

When purchasing products on the Site, bank data such as the card number or bank account indicated to make the payment, cardholder and bank account holder will also be processed.

This data may be processed exclusively by third-party companies that manage the payment methods used on the site.

Please note that the Site uses the following payment services for which please refer to their respective privacy policies for data processing:

• PayPal: https://www.paypal.com/it/webapps/mpp/ua/privacy-full
• Google Pay: https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB
• Amazon Pay: https://www.amazon.in/gp/help/customer/display.html?nodeId=202136010
• Visa: https://usa.visa.com/legal/privacy-policy.html
• Mastercard: https://mea.mastercard.com/en-region-mea/about-mastercard/what-we-do/privacy.html
• American Express: https://www.americanexpress.com/it-it/chi-siamo/legal/centro-di-privacy/dichiarazione-sulla-privacy/

III. Navigation data

Browsing data are data acquired automatically by the systems and programmes responsible for the operation of the Site and are necessary for the use of web services [e.g. IP addresses, browsers used, domain names of the systems used by users to connect to the web portal, URI notation addresses (Uniform Resource Identifier) of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment].

This data is acquired even in the absence of registration on the Site or a request for information.

Browsing data are used exclusively in aggregate form to draw up anonymous statistics on the consultation of the Site and to check its correct operation, and do not allow the users concerned to be identified; they are deleted immediately after processing in anonymous form.

They may, however, be used to ascertain liability in the event of computer crimes committed against the website.

1. Data provided voluntarily by the user

The personal data voluntarily provided by the User (such as name, surname, telephone number, e-mail address) for the purpose of sending messages to the Site and/or purchasing the products made available are used for the sole purpose of responding to the User’s needs and to comply with legal obligations.

The legal basis for such processing is the fulfilment of services inherent to the applications made and purchases made, as well as compliance with legal obligations.

The information that the User of the Site decides to make public through the services and tools made available to him/her is provided by the User knowingly and voluntarily, exempting the Site from any liability for any breach of law.

It is the User’s responsibility to check that he/she has permission to enter personal data of third parties or content that is protected by national and international regulations.

1. Data collected through analytical cookies

The Site also acquires data relating to the User through the use of cookies.

For more information on what data is processed via cookies, what types of cookies are active and how to deactivate them, please refer to the cookie policy.

These cookies are used to track the user’s browsing preferences and to collect statistical data. Users may deactivate these cookies by accessing the settings of their browser, as indicated in the Site’s cookie policy.

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B – Purpose of processing

The personal data collected are used for:

• allow products purchased by the User to be sent by e-mail;
• respond to contact requests sent by the User;
• allow the User’s use of the Customer Service;
• obtain anonymous statistical information on the use of the web portal;
• to check the correct functioning of the web portal;
• the sending of communications and newsletters, both in paper and electronic format, to the e-mail address provided by the User: in the event that the User decides to subscribe to the newsletter of www.licensel.com only after having given his/her specific consent, his/her personal data will be processed by the Data Controller for the purpose of sending commercial or promotional communications, updates relating, for example, to exclusive offers, special events and promotions. To unsubscribe from the newsletter, simply click on the unsubscribe link at the bottom of the e-mails you receive or write to [email protected].
• ascertaining liability in the event of hypothetical computer crimes against the website;
• compliance with any other legal obligation not included in the preceding purposes.

Data may only be disclosed following a request by the Judicial Authority within the terms of the law.

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C – Legal basis of processing

The legal basis for the processing of personal data is the performance of the services inherent in the relationship established by signing the Terms and Conditions, the consent of the data subject, compliance with legal obligations and the legitimate interest of the Data Controller in carrying out processing necessary for these purposes.

1. Execution of a contract

The Controller processes Personal Data relating to the User when the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures.

1. Consent of the person concerned

The optional, explicit and voluntary sending of e-mails, messages or any type of communication addressed to the addresses indicated on this Site entails the subsequent acquisition of the sender’s address, telephone number or any other personal data that will be used to reply to requests. Such processing is carried out on the basis of the consent of the person concerned.

It is ensured that such processing will be based on the principles of lawfulness, correctness, transparency, appropriateness, relevance and necessity referred to in Art. 5(1) of the GDPR. Specific summary information will be progressively reported or displayed on the pages of the sites set up for particular on-demand services.

III. Fulfilment of legal obligations

Personal data may be processed without the consent of the data subject in the event that the Controller has to fulfil a legal obligation.

1. Legitimate interest of the data controller

The Controller processes Personal Data relating to the User where the processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.

1. Optional provision of data

Apart from what is specified for the fulfilment of the contract or legal obligations, for cookies and navigation data, the user is free to provide or not to provide his personal data. However, failure to provide data may result in the impossibility of obtaining the service.

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D – Modalities and duration of treatment

Personal data are processed using IT tools and in accordance with EU Regulation no. 679/2016.

The data processed will be stored for as long as necessary for the purposes described in this information notice and, therefore, for the minimum time necessary or until explicitly requested by the person concerned and in any case within the time limits imposed by law.

The Controller undertakes to take all appropriate security measures to prevent the loss and alteration of personal data, as well as any unlawful and unauthorised use thereof.

The data will be processed exclusively by persons authorised by the Data Controller, including possible data processors, representatives and public entities for the fulfilment of legal obligations, who perform their respective processing activities as autonomous data controllers.

Subjects authorised by the Controller who may process the data include, by way of example: commercial and legal department employees, as well as third-party technical service providers, hosting providers and IT companies (this list is not exhaustive). The data processed will not, however, be disclosed to unspecified recipients.

Parties authorised by the Data Controller that may process data for profiling purposes include the online marketing platforms “Klaviyo” (https://www.klaviyo.com/legal/privacy-notice) and ‘Omnisend’ (https://www.omnisend.com/privacy/) and ‘WordPress’ (https://wordpress.org/about/privacy).

The security of the information collected cannot be guaranteed against hacker attacks and, in general, against breaches of the security rules put in place to protect data.

In the event of attacks or violations, however, they will be communicated to those concerned and to the competent authorities in accordance with the law.

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E – Place of processing

Processing relating to the services of the web portal is carried out by staff identified and expressly designated for the specific purposes of the services requested and subscribed to.

For the processing operations in question, the Data Controller may use the help of external companies, forwarding agents, consultants, consortia, software and service providers operating, through identified and appointed personnel, within the scope of the intended purposes and in such a way as to guarantee maximum data security and confidentiality. In other cases, the personal data collected will not be disclosed to third parties, except with the express consent of the person concerned, with the exception of cases where disclosure to third parties is necessary to fulfil obligations imposed by laws, regulations or measures of control authorities, or is essential to protect the rights of other users or of the website itself.

Personal data will be processed and stored, solely for the above-mentioned purposes and for safekeeping and archiving, on remote servers operated by industry-leading providers that ensure compliance with high standards of protection with regard to the processing of personal data.

This may involve the transfer of data to countries outside the EU, where all or part of these servers may be located.

In particular, personal data may be transferred outside the European Union to the company “WordPress” (https://wordpress.org/about/privacy), an e-commerce plug-in used by the Site operated by the Owner.

The processing and storage of data by the aforementioned provider will take place in a third country that is ‘adequate’ within the meaning of the decision taken by the European Commission, in particular the decision on the adequacy of protection provided by the Canadian Personal Information Protection and Electronic Documents Act (Canadian Personal Information Protection and Electronic Documents Act) or certification Privacy Shield (US), or on the basis of a contractual obligation or standard contractual clauses approved by the European Commission, or of binding corporate rules approved through the specific procedure of Art. 47 GDPR.

For the transfer of data to non-EU countries, there is normally no need to wait for national authorisation from the Garante. However, the authorisation of the Garante will still be required if a holder wishes to use specific contractual clauses that have not been recognised as adequate by a decision of the European Commission or administrative agreements concluded between public authorities.

F – Rights of data subjects

During the processing, the data subject may exercise the following rights at any time:

• obtain confirmation of the existence or otherwise of the same data and, if so, to know their content and origin;
• verify the accuracy of the data, request the correction of inaccurate data, the integration of incomplete data or the updating of outdated data;
• obtain the restriction of processing where one of the cases provided for in Article 18 GDPR applies;
• request the deletion of data processed in breach of the law, i.e. in the presence of one of the other conditions laid down in Article 17(1)(b). a), b), c), e) and f) GDPR;
• to object in any case, for legitimate reasons, to their processing, or to object to their processing in the other cases provided for in Articles 21(2) and (3) and 22 GDPR;
• revoke at any time their freely given consent to the processing of personal data for the purposes specified below;
• obtain the release of the processed personal data in a format compatible with standard IT applications, in order to allow them to be transferred to other platforms of your choice, without impediments to the direct transmission of the processed data to another data controller, where such direct transmission is technically feasible (so-called right to data portability).

Requests concerning the exercise of the aforementioned rights should be addressed to the Controller by e-mail ([email protected]).

In the event of failure or partial response by the Data Controller to the aforementioned requests, the data subject shall have the right to lodge a complaint with the Garante per la protezione dei dati personali (www.garanteprivacy.it) or judicial redress within the terms and according to the modalities provided for under Articles 77 et seq. of EU Regulation 2016/679 (GDPR).

G – Information updates

Future regulatory updates may lead to changes in the current policy, uploaded on the Site on 20.01.2023.

In the event of a change, the Holder shall give notice thereof on the Site.