PRIVACY POLICY
I – GENERAL INFORMATION
- Informazioni generali
- 1 This section contains the information relating to the website of WaveUp Globe S.r.l., accessible at the URL https://wavup.com
- 2 This privacy notice also has effect pursuant to Art. 13 of Regulation (EU) 2016/679 (GDPR – General Data Protection Regulation),concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data. The purpose of this policy is therefore to inform the Users of the website (qualifiable as data subjects pursuant to the GDPR) about the processing operations carried out by this website, the types of data processed, the methods of processing and retention periods by WaveUp Globe S.r.l.
- 3 This website is directed exclusively at Users aged 18 or over; by connecting to the site https://wavup.com and, where applicable, voluntarily providing their own data, the User declares that they are over 18 years of age.
II – PARTIES INVOLVED IN THE DATA PROCESSING
- Data Controller and Data Protection Officer (DPO)
- 1 The data controller is the natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of processing personal data. Pursuant to Art. 25 GDPR, the controller must also adopt the technical and organisational measures adequate to guarantee a level of security appropriate to the risk arising from the processing operations carried out and other relevant circumstances.
- 2 For this website, the data controller is WaveUp Globe S.r.l., registered office in Milan (MI), 20121, Via Agnello, 8.
- 3 Data subjects may contact the controller for any clarification or to exercise the rights granted under Arts. 15 – 22 of Regulation (EU) 2016/679 at the following contact details:
WaveUp Globe S.r.l., Via Agnello 8, Milan, 20121;
email: mailto:info@waveupglobe.com
Tel.: +39 02 36714501
- Data Processors
- 1 The data processor is the natural or legal person, public authority, service or other body which processes personal data on behalf of the data controller. The controller, for activities involving personal data processing connected with the management of this website, uses services provided by companies which, in providing those services, process data on behalf of the controller; such companies have been appointed, where necessary pursuant to Art. 28 GDPR, as external processors.
- Place of data processing
- Personal data are recorded and stored in electronic databases owned by the controller and, if necessary, by the external data processors; the processing operations connected with this website are carried out at the controller's premises as well as at the premises of the companies providing essential services for the functioning of the website (such as the hosting provider).
III – DATA PROCESSED
- Types of data processed
- 1 This website collects information via server log files exclusively in anonymised form, for the sole purpose of compiling statistics about site use and verifying its correct functioning. Such information will be processed based on the controller’s legitimate interests.
- 2 Through this site, the controller and the external processors may also collect and process the following personal data of Users:
- 2.1 – first and last name and/or email address of the User (only if voluntarily provided by the User, e.g., by sending an email to the controller);
- 2.2 – additional personal data of the User (only if voluntarily provided by the User, e.g., by sending an email to the controller);
- 2.3 – IP address (Internet Protocol) of the User;
- 2.4 – technical cookies
- 3 In the event of a voluntary submission by the User of their Curriculum Vitae for potential employment or collaboration, the relevant data will be examined and, if saved for future collaboration, a specific short notice compliant with applicable legislation will be provided to the User.
- Purposes of processing and data retention period
- 1 The personal data referred to in art. 5.2 are collected and processed for the following purposes:
- 1.1 – provision of the services offered by the site;
- 1.2 – responding to contact requests submitted by Users via email or contact form;
- 1.3 – sending commercial proposals to Users who have given consent to receiving them;
- 1.4 – fulfilment of legal obligations (accounting, tax, etc.).
- 2 The personal data referred to in art. 5.2 will be retained for the period strictly necessary to achieve the purposes indicated above, unless required by law to retain them for longer. The data may also be kept for the period necessary, by the controller or any processors, to ascertain, exercise or defend a right in court within the statute of limitations.
- 3 In the event that processing of personal data is based on the User’s consent, the controller may retain personal data until withdrawal of that consent.
- 1 The personal data referred to in art. 5.2 are collected and processed for the following purposes:
- Legal basis for processing
- 1 The legal bases for processing the personal data indicated in art. 5.2 are as follows:
- 1.1 – for the purposes in arts. 6.1.1 and 6.1.2, the legal basis is the provision of a service at the request of the data subject, pursuant to Art. 6(1)(b) GDPR (contractual basis);
- 1.2 – for the purpose in art. 6.1.3, the legal basis is the data subject’s free, specific, informed and unambiguous consent, pursuant to Art. 6(1)(a) GDPR (consent);
- 1.3 – for the purpose in art. 6.1.4,4the legal basis is the fulfilment of a legal obligation to which the controller is subject, pursuant to Art. 6(1)(c) GDPR (legal obligation).
- 1 The legal bases for processing the personal data indicated in art. 5.2 are as follows:
- Social Network Plugin
- 1 This website does not incorporate social network plugins and/or buttons; it only contains links to the controller’s pages and those of its main collaborators on various social networks. By clicking those links the User leaves the controller’s website and therefore the scope of this privacy notice no longer applies.
IV – DATA SUBJECT’S RIGHTS
- Rights of the data subject
- 1 Art. 13(2) GDPR lists the rights of the User.
- 2 The controller informs the User about the rights granted to them under Arts. 13(2)(b) and (d), 15, 16, 17, 18, 19 and 21 GDPR, specifically the rights of: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), objection to processing (Art. 21), revocation of consent at any time (Art. 13(2)(c) GDPR).
Requests may be sent to the controller, without formalities, or alternatively using the form provided by the Data Protection Authority, by emailing mailto:info@waveupglobe.com
- 3 Where the processing is based on the User’s consent (as indicated in Art. 6.3), the User has the right to withdraw it at any time without prejudice to the lawfulness of processing carried out prior to the withdrawal.
- 4 Simultaneously, if the User considers that the data processing operations carried out by this website violate current legislation, they have the right to lodge a complaint with the competent Supervisory Authority.
V – NATURE OF DATA PROVISION
- Nature of the User’s data provision
- 1 The provision of the personal data referred to in Art. 5.2 is mandatory for the purposes in Arts. 6.1.1. and 6.1.2: in their absence the controller will not be able to provide the requested services.
- 2 The provision of the personal data referred to in Art. 5.2 and the consent to data processing are optional for the purpose in Art. 6.1.3: in their absence the User may access the site’s services but will not receive newsletters and commercial offers.
- 3 The provision of the personal data referred to in Art. 5.2 is legally mandatory for the purposes in Art. 6.1.4: in the absence thereof the controller will not be able to fulfil its legal obligations and consequently the User will not be able to access the site’s services.
VI – TRANSFER OF DATA TO NON-EU COUNTRIES
- Transfer of User data to non-EU countries
- 1 Data will never be transferred to third countries that do not fulfil the conditions laid down in Arts. 45 and following – in particular Art. 46 – of Regulation (EU) 2016/679.
VII – SECURITY
- Security measures implemented by the controller
- 1 This website processes Users’ data lawfully and respectfully of the GDPR, adopting adequate security measures to ensure the protection of data and the related processing operations, taking into account the identified risk profiles and the need to prevent personal data breaches, such as unauthorised access, disclosure, modification or destruction of data.
- 2 Authorized personnel of the controller (employees) responsible for site management or processing of data collected via the site may have access to the data; in addition, external data processors providing outsourced services to the controller necessary for the operation of the site may have access.
VIII – COOKIE
- Types of cookies
- 1 The site https://waveupglobe.com/uses cookies intended to make navigation easier and more intuitive for the User.
- 2 Cookies are small pieces of text used to store some information relating to the User, their preferences or the device used to access the site; such information is collected to offer the User a personalised browsing experience, by remembering choices previously made and adapting the site’s operation accordingly.
- 3 Cookies may record personal information relating to the User: the User, if they wish, may delete all cookies (or some of them) following the instructions under Art. 17.
- Technical cookies
- 1 Technical cookies allow navigation of the site and facilitate access to it, as well as the use of its contents by the User. They are therefore necessary for transmitting communications over an electronic network or for the controller to provide the service requested.
- 2 Settings for disabling, managing or deleting cookies vary depending on the browser used by the User. It should be noted that, in some cases, disabling or deleting cookies may slow down or prevent access to certain parts of the site.
- 3 With regard to cookie retention periods, two types may be distinguished: temporary cookies, which are automatically deleted at the end of the browsing session and serve to enable the User’s identification so the User does not have to log in on every page visited; and permanent cookies, which are stored in the browser for a preset period or until deleted by the User.
- 4 The site may also install session cookies to allow the User access (and continued presence) in the restricted area of the site as an authenticated User until they log out.
- Third-party cookies
- 1 Based on origin, cookies may be distinguished between those sent directly to the User’s browser by the site visited and those set by third parties.
- 2 Most third-party cookies are tracking cookies used to follow Users’ online behaviour and use the information collected for the provision of services by such third parties: the operation of these cookies is subject to the rules provided by the third parties that set them, available on their respective websites, to which reference is made.
- Profiling cookies
- 1 Profiling cookies are those intended to create a profile of the User and subsequently send them advertising messages in line with previously expressed preferences.
- 2 With reference to this type of cookie, where present, the User must give explicit consent for their use.
- Browser configuration used by the User
- 1 The User may manage cookies through the settings of the browser used.
- 2 To learn in detail how to configure cookies for the main browsers available, the User may refer to the specific page for the browsers.
- 3 For further information and support on this issue, please visit the specific page for the main browsers available:
- Internet Explorer ed Edge: https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies
- Firefox: https://support.mozilla.org/it/kb/protezione-antitracciamento-avanzata-firefox-desktop?redirectslug=Attivare+e+disattivare+i+cookie&redirectlocale=it
- Safari: https://support.apple.com/it-it/guide/safari/sfri11471/mac
- Google Chrome: https://support.google.com/accounts/answer/61416?hl=it
IX – CHANGES TO THIS DOCUMENT
- Changes to the website’s privacy policy
- 1 This privacy policy, published at https://wavup.com/privacy-policy/, may be freely modified by the controller as required; accordingly, Users are invited to monitor this document regularly.
- 2 This privacy policy was last updated on 01.07.2024 to comply with the GDPR.