Information on the processing of personal data
Comuni-Chiamo S.R.L. (VAT n°03160171207), as the Data Controller operating the services "Comuni-Chiamo" and “HSE App” provided at www.comuni-chiamo.com, pursuant to Legislative Decree June 30, 2003 n°196 , pursuant to art. 13, (Code regarding the protection of personal data) as amended by Legislative Decree August 10, 2018 n°101 and subsequent amendments and additions, hereinafter referred to as "Privacy Code", and pursuant to EU Regulation 2016/679 (hereafter “GDPR”), informs you that the aforementioned legislation provides for the protection of people and other stakeholders with regards to the processing of personal data based on the principles of fairness, lawfulness, purpose limitation, necessity, accuracy, relevance, minimization and proportionality. Your personal data will be processed in compliance with current legislation in order to guarantee due confidentiality and the protection of your rights.
In order to allow an easier understanding of this document and of the reference legislation please note that:
- “Personal data”
- means any information relating to an identified or identifiable natural person; "data subject" means the person providing the data;
- “Data Controller”
- means the natural or legal person who determines the purposes and means of the processing of personal data;
- “Data Processor”
- means a natural or legal person who processes personal data on behalf of the Data Controller;
- means a natural or legal person, authority, service or other entity to whom the personal data are disclosed.
Purpose of the processing
"Comuni-Chiamo" and “HSE App” allow users to report issues of various nature in a simple and easy way, online, to public and private groups/organisations who have adopted the service, and to receive updates about the resolution of such issues directly from the aforementioned groups. These groups, for the purpose of providing the service, will be the recipients of your data. The data collected will also be used for the following purposes:
- provision and administration of the services "Comuni-Chiamo" and “HSE App”;
- provision and administration of a periodic newsletter relating to the services "Comuni-Chiamo" and “HSE App”;
- statistical processing and research relating to the service, its functionality and the fulfilment of its purpose, using data in aggregated and / or anonymous form but, in any case, in such a way that does not allow the identification of the user;
- provision of information relating to future initiatives and / or provision of new services by Comuni-Chiamo S.R.L;
- communication to third parties only to execute activities aimed at the provision, distribution and marketing of the service;
- fulfillment of the requirement established by laws, regulations and EU legislation.
Personal Data may be disclosed to specific groups considered recipients of such Personal Data. The GDPR defines the recipient of a Personal Data as "the natural or legal person, public authority, service or other body that receives communication of personal data, whether or not they are third parties". From this perspective, in order to correctly carry out all the processing activities required to fulfil the purposes referred to in this Policy, the following Recipients may find themselves in the need for processing your Personal Data:
- public Administrations, companies and other groups, public or private, who have adopted the service and to whom the reports are directed, in order to provide the service and send informative communications (hereinafter "The Members");
- companies, service providers and other groups, public or private, to whom the Members may communicate the data in order to allow them to solve the issue raised in the report;
- companies, service providers and other groups, public or private, designated to manage the issue raised in the report, to whom your data may be communicated directly;
- individuals, employees and / or collaborators of the Data Controller, who have been entrusted with processing activities on your Personal Data. These individuals have received specific instructions regarding the security and correct use of Personal Data and are defined, in accordance with article 4 point 10) of the Regulation, "persons who, under the direct authority of the Data Controller or the Data Processor, are authorized to process personal data”.
- third parties selected for the purpose of processing statistics and drawing up useful research for the study and / or evaluation and / or implementation of the service. We will make sure that these groups process the data, received in an aggregated and / or anonymous form, but in any case in such a way that does not allow the identification of the user, in compliance with the regulation on the protection of privacy;
- where required by the law or in order to prevent or suppress a crime, your Personal Data may be disclosed to public bodies or to the judicial authority without these being defined as Recipients. In fact, pursuant to article 4 point 9) of the Regulation, "public authorities which may receive Personal Data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients”.
Third-party technological services used by comuni-chiamo and HSE app
In order to provide the service Comuni-Chiamo use some third-party technological services:
The website is hosted on AWS Amazon servers localized in Frankfurt (DE)
- Google analytics (Google Ireland Limited)
- Google tag manager (Google Ireland Limited)
- Google reCAPTCHA (Google Ireland Limited)
- Widget Video YouTube (Google Ireland Limited)
- Aws Cloudfront
login, backend and cloud platform
The service is hosted on AWS Amazon servers localized in Frankfurt (DE)
- Google Gmaps (Google Ireland Limited)
- Google tag manager (Google Ireland Limited)
- Firebase Cloud Messaging
- Aws Cloudfront
Personal data will be processed as following:
- creazione di un profilo personale c.d. account;
- trattamento a mezzo di sistemi informativi e informatici, anche in forma anonima.
Data will be processed, according to the above listed principles, by a person specifically authorized by the Data Controller or by other persons entitled to do so. You may at any time request and obtain the erasure, updating, correction, integration, communication of your data and, more generally, exercise the rights arising from art 7 of the Privacy Code, and the other rights stated in the above mentioned EU Regulation.
Rights of Data subjects
- The data subject has the right to obtain confirmation of the existence of personal data concerning him or her, even if it is not yet registered, and its communication in an intelligible form. The data subject also has the right to obtain confirmation from the Data Controller whether personal data concerning them is being processed and, in this case, to obtain access to personal data.
- The data subject has the right to obtain information about:
- the source of personal data;
- the purposes and methods of processing;
- the logic involved when data processing is carried out using electronic tools;
- the identity of the Data Controller, of line managers and of the representative appointed pursuant to article 5, paragraph 2;
- the groups or categories of groups to whom personal data may be communicated or who may learn about them as representative appointed by the Government, managers or personnel in charge.
- The data subject has the right to obtain:
- the update, the adjustment and, if the case, the integration of personal data;
- the erasure, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is unnecessary to the scope for which the data were collected or subsequently processed;
- confirmation that the operations referred to in letters a) and b) have been brought to the attention, also as regards to their content, of those to whom the data have been communicated or disseminated, except in those cases where fulfillment proves impossible or involves a disproportionate effort compared to the right to be safeguarded.
- The data subject has the right to object, in whole or in part:
- for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;
- to the processing of personal data concerning them for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication.
The data subject has the right to submit a complaint to the enforcement authority (Data Protection Supervisor). Each processing takes place in compliance with the methods set out in articles 11, 31 and subsequent of the Privacy Code and through the adoption of the minimum security measures provided by the technical specification (Annex B). The processing of data takes place, in any case, through techniques adequate to their protection and according to the principles and indications set out in EU Regulation 2016/679.
How to request the erasure of your data
Send a request to firstname.lastname@example.org using the email you have used to register for the service and we will erase all your personal data as soon as possible.
Where your data is stored
The data that Comuni-Chiamo and HSE App collect to provide the service are stored within the EEA territory on Amazon AWS servers (GDPR Amazon).
The provision of your data is not mandatory; however, failure to provide, even partially, the data indicated as "required" for the provision of the service, make it impossible for Comuni-Chiamo S.R.L. to provide the service. The legal basis of the data processing is the explicit consent that you provide by clicking "I accept" at the bottom of this text. In any case, during the provision of the service, only the data strictly required for the aim pursued will be recorded and processed. From the end of the service, the data will be kept exclusively for statistical purposes for a period of time in any case not exceeding 10 years. Under no circumstances you will be requested any sensitive, genetic, biometric, judicial and health related data.
Data controllor and processor
The Data Controller is:
Via San Martino n. 26/1 - Monte San Pietro CAP 40050, (BO)
VAT, Tax Code and registration number at the Chamber of Commerce of Bologna 03160171207
The Data Processor is:
DECLARATION OF ACCEPTANCE
The undersigned, by clicking "accept" below, confirms that they have read and understood what is indicated in this statement and explicitly confirms that he has been previously informed by the Data Controller about: a) the purposes and the methods of processing the data; b) the nature of providing data; c) the rights referred to in art. 7 of Legislative Decree June 30, 2003 no. 196 and EU Regulation 2016/679; d) the identity of the Data Controller and line manager. For receipt and acknowledgment pursuant to art. 13 of Legislative Decree June 30, 2003, No. 196 and art. 12 of the EU Regulation 2016/679.