TANAZA PRIVACY POLICY PURSUANT TO ITALIAN LAW AND GENERAL DATA PROTECTION REGULATION (GDPR)
TANAZA respects Your privacy and understands Your need to protect the personal information that you share with us.
This privacy policy describes the terms and the purposes of the collection, processing, use and disclosure of personal data and other information provided by visitors and users of our websites (the “Websites“), as well as of all applications, widgets, software, features, tools, and other services provided by us and on which a link to this Policy is displayed (collectively, together with the Websites, hereinafter our “Services“).
The parties acknowledge that:
– the term “Visitor” is referred to who merely browses the Websites and who provides personal data in order to do interactive demos, to test features or to carry out activities, such as downloading brochure or free firmware authorized by TANAZA and specified in the Websites;
– the term “User” is referred to who has registered with TANAZA directly or through reseller, partner or distributor in order to access and activate TANAZA’s Services (including trial version) according to TANAZA’s Terms of Use and Conditions (see www.classichotspot.com/Legal).
When we refer to the Visitor and the User indifferently, we use the term “You”.
By using our Services, You consent to the collection, processing (even automated), use and disclosure of Your data in accordance with this Policy, which is incorporated by reference into the TANAZA’s Terms of Use and Conditions (www.classichotspot.com/Legal). You consent as well the collection, processing (even automated) and use of Your data by TANAZA data center and its providers located in different Country (Europe and USA) in order to ensure better performance and reliability.
Tanaza’s Sites and Services are not intended for children under 18. Tanaza does not intentionally collect data related to children under 18. In the event that data referring to minors were unintentionally registered, please contact us at privacy@tanaza.com and we will promptly cancel them.
1. Processed data (hereinafter collectively, the “Data”).
1.1. Voluntarily – Provided Data.
1.1.1. To have access to, to activate and to use the Services the User and Visitor may be required to provide some personal data, such as:
– First and last name or company name;
– Address/corporate address;
– E-mail address;
– Home/mobile phone number;
– Etc.
1.1.2. The User may be required to provide additional identification Data such as, by way of example but not limited to, date of birth, gender, area of interest.
1.1.3. Further personal information voluntarily provided by User and Visitor, for example, Data of the public profile of social networks that the User or Visitor has decided to make visible and public (such as photos, video, etc.), may be collected, processed and used according to this Privacy Policy. For more information on the collection and use of such Data by social networks in general, and the rights and methods available to protect the privacy of the person concerned in that context, see the specific privacy policy followed by the social network.
1.1.4. Additional identifiable Data related to a person and/or a company and the activity carried out by the latter may be requested when the processing of the Data is necessary in order to establish a professional and/or commercial relationship.
1.2. Passively – Provided Data.
1.2.1. When You visit our Websites or use our Services, additional Data are collected automatically. Computer systems and software procedures aimed at the functioning of websites collect, during their normal running, some Data whose transmission is implied in the use of Internet communication protocols. Such Data, due to its nature, could allow the identification of Users and/or Visitors and network devices, also through the processing and association with Data held by third parties.
This category of Data includes, for example, IP addresses or domain names of computers used by Users and Visitors who connect to the Websites, the URI (Uniform Resource Identifier) of the requested resources, the time of the request, the method used to make the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (such as, successful, error, etc.) and other parameters regarding the operating system, network devices, computer environment and communication protocols of Users and Visitors. Also such Data may be processed in accordance with this Privacy Policy.
2. Purposes of the processing.
2.1. The Data processing, even automated, is aimed at the Services access, activation and providing of the Services.
2.2. Data may be also processed, even automated, by us or by our business partners for several purposes in connection with our business, by way for example but not limited to:
2.2.1. in order to answer Your questions, to personalize your experience on our Websites, and to keep You up to date on the latest features announcements, software updates, special offers or other information;
2.2.2. in order to obtain statistical information related to the use of the Services and to verify their proper operation;
2.2.3. in order to send descriptive, promotional, and informative material.
2.3. In cases referred to in 1.1.4. Data may be processed, by way for example but not limited to, to verify compliance with the agreements and software licenses, to track downloaded software or track use of other available Services on our websites or portals.
2.4. Data may be processed for the fulfillment of the obligations set forth by applicable laws and it may also be provided to the competent authorities, which may request for it. Data may be used in order to ascertain unlawful activities.
2.5. Data are monitored to prevent abuse, such as:
− attempting to gain unauthorized access to the Services, other accounts, computer systems or networks connected to the Services, through password mining or any other means;
− transmitting any material that contains viruses, Trojan horses, worms, time bombs, cancelbots, or any other harmful or deleterious programs;
− interfering with or disrupting networks connected to the service or violating the regulations, policies or procedures of such networks;
− creating a false identity or otherwise attempting to mislead others as to the identity of the user that is utilizing the Websites;
− violating intentionally or unintentionally any applicable local, state, national or international law.
3. Modalities of Data processing.
3.1. Data processing will be carried out in accordance to the principles of correctness, lawfulness and transparency and in accordance to the principle of privacy protection and User-Visitor rights.
3.2. Data will be processed through the use of tools and procedures, even automated, suitable for granting the security and confidentiality pursuant to applicable laws. The processing of Data can be carried out either by paper or electronic media.
3.3. In accordance with the principles of legality, purpose limitation and the minimization of the data, also pursuant to art. 5 GDPR, Data will be processed for no longer than is necessary for the purposes for which the Data are collected or for which they are further processed.
3.4. Data will not be disclosed with exception of these cases:
3.4.1. Data may be disclosed to services vendor or in general to every subject who practice activities aimed at provide Services (for example, payment system provider, CRM provider, marketing automation software provider).
3.4.2. Data may be disclosed and handed over to possible buyer, replacement or cessionary in case of merger, takeover, debt loan, company assets sale or other similar transactions.
3.4.3. Data may be disclosed to commercial and channel reseller, partner, and distributor.
3.4.4. Data may be disclosed to connected enterprises, which in turn may process Data in accordance with their privacy policy.
3.5. The Websites may present link to a different websites, managed by a different company, which is not managed by TANAZA. TANAZA is not liable for these Data processing or disclosures. You are required to verify the privacy policy of those websites and to consent to the collection, processing and use of Your personal Data in accordance with those policy.
3.6. Specific security measures are implemented in order to prevent Data loss, illicit or improper use, and unauthorized access.
4. Nature of the Data processing.
4.1. The consent to the processing of Data for the purposes mentioned in clauses 2.1, 2.3, 2.4 and 2.5 must be considered mandatory. Failing that, the User or Visitor may be denied access to, activation and providing of the Service .
4.2. The consent to the processing of Data for the purpose of sending descriptive, promotional and/or informative material regarding our activities and for products and Services as mentioned in clause 1.1.4 must be considered optional.
5. Data Controller.
5.1. Data controller is TANAZA, or any company who TANAZA will appoint as Data processor.
5.2. Data processing will be performed by TANAZA’s employees, or associates, or by anyone acting, in any case, as persons in charge of the processing.
6. Users’ and Visitors’ rights pursuant to art. 7 Italian d.lgs. 196/2003 and to Regulation (EU) 2016/679 (GDPR).
6.1. Pursuant to art. 7 Italian d. lgs. 196/2003, the User and the Visitor shall exercise these rights:
– the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form;
– the right to be informed:
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated;
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing;
– the right to obtain:
a) updating, rectification, or where interested therein integration of the data;
b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
– the right to object, in whole or in part, a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
6.2. Starting from May 28, 2018, the date on which GDPR becomes directly applicable in all the Member States, within the limits and terms set forth in articles 15-22 of the same Regulation, the User and the Visitor are entitled to the right:
– to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data;
– if the processing is based on explicit consent of the data subject for one or more specific purposes, to withdraw the consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
– to lodge a complaint to the supervisory authority (Italian Authority Responsible for Privacy).
7. Transfer of personal data abroad
7.1. Visitors and Users are informed of the possibility that their Data, for the purposes of preservation and provision of the Services, are transferred on servers located in West Virginia (USA), that guarantee a suitable and safeguards level of protection pursuant to article 45 GDPR.
7.2. In accordance with paragraph 3.4, on the disclosure the Data to third parties, Data may also be transferred abroad, if the mentioned third parties are settled in a country other than Italy.
8. Changes to this Privacy Policy.
8.1. TANAZA reserves the right to update and amend this Privacy Policy.
8.2. The updated version shall be effective upon posting on the Websites.
8.3. The User and the Visitor are required to periodically review this Privacy Policy and any potential update and amendment.
8.4. The uninterrupted use of the Services by the User or the browsing by the Visitor after the publication of the new Privacy Policy constitutes acceptance and acknowledgement of such amended version of the Privacy Policy by the User or the Visitor.
9. Governing law and forum
9.1. This Privacy Policy is compliant to Italian d.lgs. 196/2003 and Regulation EU 679/2016 (GDPR), directly applicable in all the Member States starting from May 28, 2018.
9.2. The User and the Visitor may exercise their rights by sending a written notice to TANAZA at privacy@tanaza.com.
9.3. Data collection and processing will be carried out pursuant to, and governed by, Italian law and GDPR..
9.4. The exclusive jurisdiction to settle any dispute concerning the content, interpretation and implementation of this Privacy Policy is set by the Court of Milan.
Cookie Policy
TANAZA uses cookies. To learn more about it, you can consult the Cookie Policy (see www.classichotspot.com/Legal).
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If you have any questions or comments about this policy, please contact us at privacy@tanaza.com.
Last Modified: May 2nd, 2018