Last Updated: June 1, 2022
Dear Visitor of the Site, complying with privacy law is particularly dear to us.
“Processing of Personal Data“, in plain words, means any operation concerning any information relating to an identified or identifiable natural person. For example, first and last name, or an email address with a “user name” that identifies You (e.g. email@example.com) is considered “Personal Data”, and the actions of collection, registration with us and use of Your Personal Data to send You a communication are considered “Processing” operations; same applies to communication of Data to other organisations and storage.
Our organisation is defined as the “Data Controller“, meaning that We are the entity that establishes how and for what purposes information relating to natural persons are processed.
You, as an individual whose Personal Data We process, are referred to as “Data Subject” and are entitled to receive the following information about who We are, what Personal Data We process, why, how and for how long We process it, and what obligations and rights You have in this regard.
If You are a natural person or a sole proprietorship, You are the Data Subject; if You are a private or public organisation (e.g. a corporation, association, public body), the Data Subjects are the natural persons who administer the organisation itself or who operate under its authority (e.g. its employees); information strictly related to the organisation (e.g. tax code number or VAT number) is not considered Personal Data.
Depending on whether You are a simple Visitor, sending us a Request through the Contact Form, and/or at the addresses You can find at the “Contact” Page, or in case You want to subscribe and use the Services, we collect and/or we require You to provide us with Data, necessary to permit You to browse our Site and/or receive our answers to your requests relating to the Services.
Who are we (“Data Controller”)?
Public Pressure Ltd., a company duly existing and incorporated under the laws of Ireland, with registered office in 3rd Floor, Ulysses House, Foley Street, Dublin 1, Ireland, D01 W2T2 registered at the Registrar of Companies of Dublin with Number 701750, VAT no. IE-3929949FH.
What categories of Personal Data do we process?
Personal data included in the registration page and checkout at the minimum extent needed to fulfil each of the Purposes shown below. We process all the Data You supply when writing an email. We require You not to include in the communications You send us any “particular information” referred to You or others (e.g. health data).
In order to allow You to browse the Site, we process Browsing Data, which sometimes does not consist of Personal Data because it cannot allow your Identification. For further information on the meaning of Browsing Data and whether they consist of Personal Data, You can consult the proper Glossary entry at the end of this Policy.
Why do we process Personal Data (Purpose) and what is the basis for the Processing (Legal Basis) of each category of Data?
|N.||Purpose||Categories of Personal Data||Legal basis|
|1||The need to make the Site available in accordance with the GTCs; analyse the traffic on the Site (e.g. detect the most visited pages, the number of visitors per time slot or day, geographical areas of origin, etc.) to understand how the Site is used, in order to manage, optimise, and improve it, or even just for statistical purposes; solve operational problems (e.g. anomalies in page loading).||Browsing Data, anonymous information (which does not allow us to trace your identity) and Common Personal Data (e.g. full IP address).||The performance of the contract.|
|2||To perform monitoring activities to reject and/or prevent cyber-attacks and frauds (security of the system).||Browsing Data, anonymous information (which does not allow us to trace your identity) and Common Personal Data (e.g. full IP address).||Our legitimate interest of keeping our Site secure.|
|3||To satisfy your requests regarding the Site and our activities received at the contact details on the “Contacts” page through the Contact Form or through other means.||Common Personal Data.||The performance of the contract.|
|4||Provide the Services and perform all the activities. related and subsequent.||Common Personal Data.||The performance of the contract.|
|5||Direct Marketing (sending advertising material, commercial communications, direct sell, market’s interviews, appreciation questionnaires) toward Lead and/or Prospect, also through the Newsletter.||Common Personal Data (email address).||Your consent, freely given and withdrawable at any time.|
|6||Marketing communications relating to products or Services similar to those You have already purchased or negotiated with us, sent to the e-mail address previously provided by You (“soft spam” or “soft opt-in”).||Common Personal Data (e-mail address, service provided).||Our legitimate interest in consolidating our business relationship with You, unless You inform us that You wish to object it.|
|7||Compliance with obligations under Applicable Law and/or orders issued by Authorities.||Common Personal Data.||The performance of the contract or the need to comply with legal obligations.|
|8||Establish, exercise and/or defend legal claims.||Common Personal Data.||Our legitimate interest in exercising or defending our rights.|
To whom do we communicate the Data (Categories of Recipients)?
To the minimum extent necessary to achieve each of the Purposes, to:
- persons/entities who provide us with services and process data on our behalf as Site, Data Processors (e.g. software and hardware providers, email marketing providers, other IT service providers, the accountant, our consultants, etc.);
- our personnel committed to confidentiality or subject to a legal obligation to confidentiality;
- public or private entities to whom we are required to communicate the data in accordance with the law.
Do we transfer Personal Data outside the European Economic Area?
Some of our IT service providers are based in countries that may not have equivalent privacy and data protection laws to the country in which You reside.
We ensure that when we transfer information of users in the EEA, the UK or Switzerland to third countries the transfer will take place only in presence of an adequacy decision or on the basis of the Standard Contractual Clauses (SCCs) which have been approved by the European Commission and other appropriate measures to safeguard the transfer. We invite the Visitor/ User to contact us for further information about the transferral of Personal Data outside the European Economic Area, the UK and Switzerland.
How long do we retain the Data?
The maximum extent of storage time is related to the provisions of the Applicable Law which allow us to (or obliged us to) retain the Data to protect our rights or until You exercise your right to object to the processing (if and to the extent that it is applicable).
We process Personal Data for Marketing purposes until the withdrawal of the consent (or until You unsubscribe from the Newsletter). If You write to us for information through the Contact Form and/or at the addresses on the “Contacts” page we will hold your data for a maximum of one year from the request. The Browsing Data persists no longer than seven days (except for any need to ascertain crimes by the judicial authority).
Not at the moment.
Are You obliged to provide us with Personal Data?
Due to the operation of the Internet network, You may not refuse to communicate your Browsing Data; it is not allowed to refuse to communicate some Personal Data (e.g. IP address of your device).
Of course You are not obliged to send us a request through the Contact Form or contact us to purchase our products and benefit from our Services, subscribe to the Newsletter, but if You intend to do it, then You will have to provide us with the Personal Data we need.
Also, it is not mandatory to express consent for Marketing purposes.
What happens if You refuse to communicate your Data?
If You refuse to provide us with your Data for contractual purposes, we will not be able to enter into and/or continue the Agreement.
If You refuse (initially or subsequently) the processing for Marketing purposes (e.g. Newsletter), You will not (or can no longer) be informed about news related to our activities, nor benefit from any promotions, discounts or bonuses.
What rights do You have as a “Data Subject”?
You, as the person to whom the data refer (“Data Subject”) have the right to:
- access the data held by the Controller, and to ask for a copy, unless the exercise of the right violates the rights and freedoms of other natural persons;
- request the rectification of incomplete or inaccurate data;
- request the erasure of the data, subject to the exclusions or limitations established by the Applicable Law;
- request the restriction of processing, if the conditions are met and subject to the exclusions established by the Applicable Law request data portability (i.e. commonly used and machine-readable format, so that they can be transmitted to another Data Controller without hindrance), to the extent that the processing is based on consent or on the need to perform a contract, where technically possible and except where the exercise of the right infringes the rights and freedoms of other natural persons;
- lodge a complaint with the Data Protection Authority of your country, or of the place where the alleged violation occurred.
Right to withdraw the consent
Remember that You can withdraw the consent given at any time, but the withdrawal will not affect the lawfulness of the data processing carried out in the period prior to such revocation.
Right to object
You may object to the processing of data based on:
- the legitimate interest of the Controller, and specifically for the purpose of direct marketing upon simple request, initially (by writing to the e-mail address below) or subsequently in each communication;
- the legitimate interest of the Data Controller, at any time for reasons related to your particular situation (e.g. harm to your honour, reputation, decorum), unless the Data Controller demonstrates a compelling and overriding legitimate interest, and unless the processing is necessary for the establishment, exercise or defence of a legal claim.
Who can You contact for questions or to exercise your rights?
You may contact the Data Controller for questions concerning the processing of your Personal Data by sending an email to firstname.lastname@example.org.
- The information presented herein relates exclusively to the processing of personal data collected through this Site. In the event that You enter into a relationship with us that goes beyond simply browsing the Site or requesting information, You will receive further information regarding the processing of your personal data.
- We do not intentionally collect personal information from individuals under the age of sixteen. In the event that information about children is recorded, we will delete it in a timely manner, at the request of the person concerned or of those exercising authority over them.
“Agreement”: any agreement entered into by a Data Subject with our company.
“Applicable Law”: any provision of laws and regulations, applicable to the processing of personal data through the Site.
“Browsing Data”: are the data that the computer systems and software procedures used to operate the Site acquire, during their normal operation, and whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified Data Subjects, but given their very nature, this information could, through processing and association with data by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the Site, 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 operating system and computer environment of the user. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning and is deleted immediately after processing.
“Contact Form”: means any online form provided by us through the Site, composed of one or more pages, through which the Visitor can send information or make requests.
“Cookies“: short fragments of text (letters and/or numbers) that allow the web server to store information on the browser to be reused during the same visit to the Site (session cookies) or afterwards, even after days (persistent cookies). Cookies are stored, according to the user’s preferences, by the individual browser on the specific device used (computer, tablet, smartphone). The following categories are considered:
- Technical cookies: these cookies are essential for the correct functioning of the Site and are used for the sole purpose of transmitting a communication over an electronic communication network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or User to provide such service.
- Analytical cookies: these cookies are used to anonymously collect and analyse the Site’s traffic and usage. These cookies, while not identifying the user, allow, for example, to detect if the same user logs in again at different times. They also make it possible to monitor the system and improve its performance and usability. The deactivation of such cookies can be performed without any loss of functionality.
- Profiling cookies: these cookies are persistent ones used to (anonymously or otherwise) identify your preferences and improve your browsing experience.
- Third party cookies (analytical and/or profiling): these cookies are generated by organisations not part of the Site, but integrated into parts of the Site page. For example, Google widgets (e.g. Google Maps) or social plugins (Facebook, Twitter, LinkedIn, Google+, etc.).
“Data Processor“: “a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller”, as defined in Article 4, sub-paragraph 1, no. 8, of the GDPR and the UK GDPR.
“GDPR“: Regulation (EU) 2016/679 “on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)”.
“Processing“: “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”, as defined in Article 4, subparagraph 1, no. 2, of the GDPR.
“Recipient“: means “a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not”, as defined in Article 4, sub-paragraph 1, no. 9, of the GDPR.
“Restriction of processing“: “the marking of personal data stored with the aim of limiting their processing in the future”, as defined in Article 4, sub-paragraph 1, no. 3, of the GDPR and the UK GDPR.
“Supervisory Authority”: the independent public authority in charge of monitoring the application of the privacy law).
“Visitor“: the natural or legal person who uses a device and navigates, through the Internet, on the public pages of the Site.
“Site“: the web pages displayed through https://www.publicpressure.io subdomains included.