Version of 15th September 2021
- Type of personal data and purposes of the processing
The IT systems and software procedures, that have been set up to operate this Website, collect personal data as part of their ordinary functioning; the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected in order to relate it to identified data subjects; however, in consideration of its nature, such information might allow the identification of the Visitors, through processing and matching with data held by third parties. This category of data includes IP addresses and/or the domain names of the computers used by the Visitors connecting with this Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the Visitor’s operating system and computer environment. These data are only used to obtain anonymous statistical information on Website use as well as to check its functioning; they are erased immediately after being processed. The data might be used to assess liability in case computer crimes are committed against the Website. Browsing data are processed for the legitimate interest of the Company in order to ensure the security of the Site, to check its correct functioning and to obtain statistics on its use (Sect. 6(1)(f) of the Regulations).
Data supplied by the Visitors on a voluntary basis
The voluntary, explicit and optional sending of e-mail messages to the addresses indicated on this Website on in contact forms published implies the collection of the sender’s address, which is necessary in order to reply to any request, as well as of such additional personal data as is contained in the message(s). The processing is lawful because it is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Sect. 6(1)(b) of the GDPR).
Save as specified for the browsing data, the Visitor does not have an obligation to provide the data requested in the contacts forms on the Website. However, failure to provide such data may result in the impossibility to obtain what has been requested.
- Other processing purposes: newsletter
Subject to the Visitor’s consent (Sect. 6(1)(a), GDPR), the personal date will be processed by U-First for sending newsletter (e.g. advertising material, direct sale, market research and commercial communication) in order to contact the Visitor by email and propose the purchase of products or services offered by U-First. The Visitor’s consent is optional and, failing to provide such consent, the Visitor will not experience any detrimental effect and his/her possibility to visit the Website and receive a reply or the requested material will not be jeopardized. The Visitor may in any case opt-out at any time from receiving further promotional communications by clicking on the link in the e-mail or by contacting U-First as further below indicated.
- Processing means
Personal data are processed with electronic and non-electronic means, duly taking into account the relevant processing purposes, and in any case by ensuring the security and the confidentially of the data.
- Persons to whom the data may be communicated and data dissemination
U-First’s employees or collaborators entitled to manage the Website and reply to the Visitors’ requests or send the promotional communications may have access to the Visitors’ personal data. Such individuals, who have been formally appointed by U-First as persons in charge of the processing, will process the Visitors’ personal data exclusively for the purposes indicated in this policy and in accordance with the provisions of the Privacy Code and of the GDPR.
Furthermore, third parties appointed by U-First as external data processors, such as, by way of example, IT and logistic service providers for the operation of the Website, outsourcing and cloud computing service providers, professionals and advisors, marketing companies sending marketing communications, which process the Visitors’ personal data on behalf of U-First, may have access to the Visitors’ personal data. Visitors have the right to obtain a list of the possible data processors appointed by U-First, by submitting to the latter a written request by certified mail, email or fax.
The Visitors’ personal data will not be communicated to third-party data controllers nor disseminated.
Some of the above mentioned collaborators or service providers are located outside the European Economic Area. In particular, they are located (i) in the United Kingdom based on the adequacy decision issued by the European Commission on July 28th 2021; (ii) in the United States, where the transfer is made on the basis of standard contractual clauses (Commission Implementing Decision (EU) 2021/914 of June 4th 2021); and (iii) in the Republic of Ecuador, where the transfer is made on the basis of standard contractual clauses (Commission Implementing Decision (EU) 2021/914 of June 4th 2021).
UFirst has carried out a prior study and analysis of the U.S. legislation on the processing of personal data to ensure that the United States complies with the obligations prescribed by the standard contractual clauses and offers an adequate level of protection of uFirst Users’ personal data.
We will also continue to monitor the evolution of systems for international data transfers under the Regulation and we are committed to conducting data transfers in a lawful manner in accordance with applicable data protection laws from time to time.
- Data subjects’ rights
Visitors, without charge and without any formality, may exercise the following rights under Sections 15 to 22 of the Regulation: the right to request access to personal data (i.e. the right to obtain from the Company confirmation that it is or is not processing data concerning them and, in this case, to obtain access to personal data, obtaining a copy, and the information referred to in Sect. 15 of the Regulation) and rectification (i.e. the right to obtain the rectification of inaccurate data concerning them or the integration of incomplete data) or erasure of the same (i.e. the right to obtain the erasure of data concerning them, if one of the reasons indicated in Sect. 17 of the Regulation) or the limitation of the processing concerning them (i.e. the right to obtain, in the cases indicated by Sect. 18 of the Regulation, the marking of the data stored with the aim of limiting their processing in the future), as well as the right to data portability (i.e. the right, in the cases indicated by Sect. 20 of the Regulation, to receive from the Company, in a structured, commonly used and machine-readable format, the data concerning them, as well as to transmit such data to another data controller without hindrance). Visitors also have the right to withdraw their consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on the consent before the withdrawal. Visitors also have the right to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them in accordance with Section 6(1)(e) or (f) of the Regulation, including profiling on the basis of these provisions.
The Visitor also has the right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it).
- How to contact the Data Controller and how to exercise the rights of the Data subject
Visitors may contact the Data Controller and/or the above-mentioned rights can be exercised by contacting U-First by (i) registered mail to the address “Via Giovanni Amendola n. 46, 00185 Rome (Italy)”, (ii) fax to the number +39 06 87811673 or (iii) by email to the email address email@example.com.