Privacy Policy

Easy-Trend S.r.l., with registered office at Via Cascina Tavani 10/A, 24030 Mozzo (BG), acting as Data Controller of personal data (hereinafter: the “Controller” or “Easy-Trend”), recognises the importance of protecting personal data, which it considers one of the primary objectives of its business.

Before communicating any personal data to the Controller, we therefore invite you to read this document carefully (hereinafter: the “Privacy Policy”), as it contains important information on the processing of personal data and on the security measures adopted to guarantee its protection in full compliance with the applicable legislation. This Privacy Policy is provided pursuant to art. 13 of the European General Data Protection Regulation (“GDPR”) to those who interact with the website and complies, where applicable, with Legislative Decree 196/2003 (the “Privacy Code”), as last amended by Legislative Decree 101/2018 in the applicable parts. This Privacy Policy does not apply to any websites consulted through external links.

The Controller informs you that the processing of your personal data will be guided by the principles of fairness, lawfulness, transparency and protection of your privacy and your rights. Your personal data will therefore be processed in accordance with the provisions of the GDPR and the protection obligations set out therein.

Table of contents

1. Data Controller, data processors and data protection officer (“DPO”);
2. The personal data processed;
3. Purposes of the processing and mandatory or optional nature of providing the data;
4. Processing methods, security and place of processing;
5. Disclosure and dissemination;
6. Data retention;
7. Your rights;
8. Amendments.

1. Data Controller, data processors and DPO

Consulting and using the Website may involve the processing of data relating to identified or identifiable natural persons. The identifying details of the Data Controller and operator of the Website are the following: Easy-Trend S.r.l., with registered office at Via Cascina Tavani 10/A, 24030 Mozzo (BG), VAT no. 04602200166.

The list of data processors may be requested by sending an email to: privacy@easytrend.finance.

2. The personal data processed

Browsing data

The computer systems and software procedures used to operate the Website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of internet communication protocols. This is information that is not collected in order to be associated with identified subjects, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the devices used by users connecting to the Website, the URI (Uniform Resource Identifier) addresses 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 computing environment.

This data is used in order to obtain anonymous statistical information on the use of the Website and to check that it is working correctly, to allow the correct delivery of the various features requested by the User and for security reasons, and is deleted immediately after processing. Under no circumstances does the Controller cross- reference such information with any other data in its possession in order to track the activities of specific users.

Data provided voluntarily by the user

To access the features offered through the Website and reserved for registered users, registration is required through the following personal data: first name, last name, email and telephone number. Once registration has been completed, within the User's personal area it will be possible to enter further data relating to their profile, such as date of birth, tax code, nationality, gender and city of residence.

This data is provided voluntarily and will be processed in full compliance with data protection legislation. Failure to provide this data will have as its only consequence the impossibility of creating an account and accessing certain features. The User is responsible for the accuracy of the data entered in their profile and guarantees that it is correct.

Access to the Website and the services may take place using credentials provided by a third party, such as Google, Facebook or a similar service (“social log-in”). In that case, the User must check the settings of that service and read the third-party provider's policies carefully, as they may authorise the third-party provider to share their personal information. Such data is retained for the time necessary to provide the services requested and, also for further periods, where retention is required by law or for other legitimate purposes such as Easy-Trend's defence in legal proceedings.

Information on the use of cookies

Cookies are small text files that the websites visited by the User send to and record on their computer or mobile device, to be transmitted back to those same websites on the next visit. There are two macro-categories of cookies: technical cookies, which are necessary for the website to work correctly and to allow browsing, and profiling cookies, which create user profiles in order to send advertising messages in line with the preferences expressed while browsing. Cookies can always be disabled through your browser settings. The detail of the categories and providers is set out in the Cookie Policy.

3. Purposes of the processing and nature of providing the data

The data provided to us by the user through the Website will be processed by the Controller for the following purposes:

• Delivery of the services requested (e.g. contact requests, newsletter subscription, registration, resolution of issues connected with the use of the Website, complaints). Providing the data is optional, but failure to do so may make it impossible to operate the features requested.
• Research and statistical analysis on aggregated or anonymous data, without the possibility of identifying the User, aimed at measuring how the Website performs, its traffic, and at assessing its usability and interest.
• Compliance with legal obligations, regulations or EU legislation. Providing the data is mandatory: failure to do so would not allow the Controller to meet the obligations laid down.
• Marketing: subject to explicit and specific consent, for sending promotional and marketing communications, including newsletters and market research, through automated tools (sms, mms, email, push notifications, fax) and non-automated ones (paper mail, telephone with an operator). The legal basis is art. 6(1)(a) GDPR. Commercial profiling and direct marketing processing are optional and depend on your free choice; failure to give consent will not affect your use of the services.

4. Processing methods, security and place of processing

Your personal data is processed by the Controller – or by third parties selected with care for their reliability and competence and appointed as data processors – solely for the purposes specified above, mainly by automated means but also in paper form, for the time strictly necessary to achieve the purposes for which it was collected. Specific security measures are observed to prevent data loss, unlawful or incorrect use and unauthorised access, in full compliance with the applicable legislation.

5. Disclosure and dissemination

Your personal data may be made known to employees or collaborators of the Controller belonging to the categories of administrative, commercial, legal and accounting staff or IT system administrators who, operating under the direct authority of the Controller, are appointed as processors or persons authorised to process data pursuant to arts. 28 and 29 of the GDPR. The data may also be disclosed to external parties whose activity is necessary and functional to the provision of the Website's features: professionals providing assistance and advice to the Controller; parties, bodies or authorities to whom disclosure is mandatory by law; parties entrusted with activities connected to the purposes indicated (including technical maintenance work); commercial partners and service providers involved in software development and in the delivery of services connected with the Website.

Your personal data will not be disseminated by the Controller, save with your express specific consent. Your data may be transferred abroad, to countries within the European Union or to countries outside the European Union that have received an adequacy decision from the Commission, or to countries that have not received such a decision, in compliance with and within the limits of arts. 44–49 of the GDPR.

6. Data retention

Personal data is stored and processed through computer systems owned by the Controller and managed by the Controller itself or by third-party technical service providers. The data is processed exclusively by specifically authorised personnel. The data will be retained for the time strictly necessary for the contractual or legal purposes for which it was provided to the Controller and, in any case, for no longer than ten years from the end of any relationship with the Controller.

7. Your rights

At any time you may exercise, pursuant to articles 15 to 22 of the GDPR, the right to:

• request confirmation as to whether or not your personal data exists and obtain information on the purposes of the processing, the categories of data, the recipients and the retention period;
• obtain the rectification and erasure of the data;
• obtain restriction of the processing;
• obtain data portability, receiving the data in a structured, commonly used and machine-readable format, and transmit it to another controller without hindrance;
• object to the processing at any time, including for direct marketing purposes;
• object to automated decision-making in relation to natural persons, including profiling;
• withdraw consent at any time without affecting the lawfulness of processing based on consent given before its withdrawal;
• lodge a complaint with a supervisory authority (Autorità Garante per la protezione dei dati personali — www.garanteprivacy.it).

Requests may be submitted by sending an email to: privacy@easytrend.finance.

8. Amendments

This Privacy Policy may be amended to reflect legislative or technological changes, changes in the collection and use of data, or to allow us to add new features or services. In the event of amendments, we will notify you by means of a notice published on the Website's home page and/or by taking any other action we deem appropriate. The amendments will take effect from the moment of their publication, and browsing the Website after that moment will constitute acceptance of those amendments.