This document aims to describe the modalities of treatment and management of personal data from the website Hubwit.com and its associated. In particular with reference to the collection and processing of personal data of all Users, they could be both “Registered Users” (“Sellers” / “Buyers”) or simple “Unregistered Users”, that are visiting the site.
Owner and Manager of the treatment
1) The data controller is the company LOEM Sas, based in Giovanni Plana 9 Street, P.I. IT10495580010, registration number in the register of Economic Activities, REA, TO-1138107, email address: firstname.lastname@example.org ( hereinafter, for brevity “LOEM”).
2) Responsible for processing under Article. 29 of Legislative Decree 196/03 is the firm LOEM Sas.
Collection and processing of data
3) LOEM collects and treats all personal data of the "Users" in full compliance with the Italian national legislation on personal data and in particular D.Decree 196/2003 and the Recommendation. 2/2001 made by the Working Group for the protection of personal data of the European Union.
Obligation to provide data
4) The collection of personal data that is required is an essential prerequisite for access to some services offered on the website Hubwit.com. And also for the proper management in the interests of the "Users". In particular, in order to use certain services of the site and be registered as "Sellers" or "Buyers", you must subscribe to the site, filling out a registration form.
5) The missing data, as well as conferring partial or inaccurate details, has the effect of preventing the proper delivery of the service. The '"Registered User" is committed to constantly update and correct their personal information.
6) The services offered on the website Hubwit.com are reserved only for adults. The "User" declares, by registering, that have already turned 18 and can validly give their consent and properly dispose of their rights.
7) When "Users" create an account, some information may be provided to other "Users". In particular, they will be displayed the account opening date, the age and sex (where the '"Registered User" has decided to make them public), or the profile picture, if present.
8) "Users" are aware that any personal information or content deliberately spread online, may be collected and used by third. LOEM is not responsible for any use made by these third parties.
Type of datas and treatment purpose
9) The treatment relates to common personal data (such as personal details, telephone number and e-mail address), as well as data concerning habits, consumer preferences and choices.
10) The treatment does not include any sensitive or judicial data.
11) Among the purposes for which the data are provided, must be considered included any promotional activities, market researches, marketing studies, and advertising initiatives undertaken by LOEM or any third parties who carry out these activities. Among the goals is also designated for possible sale or communication to third parties of data collected in relation to the "Users", except the right of them ("Users") to object it.
12) The provision of personal information marked with an asterisk on the registration form (name and surname, date of birth, e-mail) is required in order to complete the registration process. Consequently, the missing, partial or incorrect entry of such datas will make invalid the registration and the “User” will not be able to use the services.
13) The "Sellers" can freely decide whether to use their PayPal account or credit card. In case where the "Seller" opts for the payment through PayPal, he is obliged to provide details of his PayPal account. However if he decides to use a credit card, the "Seller" will be required to enter from time to time, at the time of payment, the details for the credit card used.
14) The datas which are not marked with an asterisk (such as a second e-mail, a mobile phone number or consumption preferences) is purely optional: their missing, partial or incorrect entry will not prevent the access to the site and the subsequently subscription to the services offered.
15) Computer systems and software procedures used to operate the website Hubwit.com acquire, in their normal operation, some personal information such as temporary markers (cookies), Web beacon and information about the register files, whose transmission is implicit in the use of Internet communication protocols.
16) The "Users" can, via the menu of your browser, choose not to authorise a cookie or request to be notified when a cookie is stored. If the "Users" deny the permission or gives only a partial authorisation to store the cookies, it is possible that this involves the reduction of the functionality of the website Hubwit.com or of the individual services.
17) LOEM maintains technical data related to the connections (log) to enable the security controls required by the law, in order to improve the quality of our services and customise them according to the "users" needs. These data do not allow the identification of the "Users" if not after a series of processing operations and interconnection, and necessarily throughout the cross-referencing of datas given from other providers. Such transactions could be made only if there is an explicit request of the competent Judiciary Authority, authorised to do so by the law that prevent or punish crimes.
18) LOEM may share with third parties certain aggregated of non-personal information nature, such as the number of people connected in a certain time or the number of users that used a particular function. This type of information does not personally identify the "Users"
Management of Advertising messages
19) LOEM does not use the data collected to send emails containing commercial or marketing purposes without the consent of the person who provided the data.
20) On Hubwit.com pages can be display ads run by LOEM or independent advertising providers. LOEM can enter the information from the users' navigation on the website Hubwit.com and from the use of some services offered in a specific cookie and communicate them to third-party advertisers in order to appear on the site targeted advertising. LOEM has no authority control on ads produced and published by independent third parties.
21) Part of the advertising proposal is generic and the same for everyone, while another part could be customised. In particular, LOEM and the independent advertising providers, in order to provide a higher interest service of advertising information, may integrate the data derived from the use of the website Hubwit.com in a specific cookie and use them to publish some targeted advertising within the website.
22) The advertising that appears, therefore, may contain information of main interest over the interests of the "Users". LOEM, as part of this automated service of customised advertising, does not store information that can personally identify the "Users".
23) The customised advertising system can be deactivated at any time by the "Users", who may at any time choose to disable the use of the cookies by the commands of their browser.
24) LOEM does not exercises any direct control over media content and information made available by the "Users". Consequently, LOEM makes no warranty, express or implicit, concerning the truth, legality, accuracy and reliability of the information and transmitted contents. LOEM is not responsible for the "Users" behaviour, who remain the only responsible for the opinions expressed, of any image, video, or published link and, in general, of any information or content transmitted, uploaded, stored or anyways made public through the site Internet Hubwit.com
Third Party Data
25) The "Users" ensure that they have obtained all the consents and the releasing (including the consent for the use of third parties datas provided by the Italian National and Community legislation on personal data - Legislative Decree 196/2003) by all persons having the right or the responsibility to provide such permissions in respect of any link published and, in general of any information or content transmitted, uploaded, stored or otherwise made public through the Internet site Hubwit.com.
26) The "Users" agree not to publish and disclose news, videos, pictures or other content such as to enable the identification of a minor subject or of a subject that has no ability to understand or want.
27) The "Users" are aware that the unlawful processing of third parties data, in order to reap profits for themselves or others or cause others a damage is criminally punishable under the Article. 167, D. Decree 196/2003.
Method of Treatment
28) The identifying marks and personal data of the “Users” are collected and can be registered, organised, stored, accessed, processed, sorted and stored by LOEM for the management and the proper operation of the website Hubwit.com and for the fulfilment of obligations provided for the law.
29) The treatment is performed by computers and in any case in compliance with the precautionary measures on security and data confidentiality, this in order to minimise the risk of unauthorised access, modification, disclosure, non consensual handling or destruction of the datas collected.
30) LOEM is committed, within the limits of current technology, to use the best efforts to update and optimise their systems of firewall, antivirus and filters, in order to minimise the risk that the website Hubwit.com and databases where such data are contained, could be attacked by third parties and to safeguard the security of its services, the integrity of traffic datas, the location data and the electronic communication with respect to any form of use or not allowed understanding .
31) The data collected and stored in LOEM databases can be used by employees and / or treatment, holder employees, as in charge bound by an obligation of confidentiality.
32)"Users" expressly consent to the possible transmission of datas outside the European Union.
33) LOEM can assign or transmit the information gathered to third parties for purposes of promotional activities, market surveys, marketing studies, marketing initiatives, advertising and commercials activities, with respect to which the user will still have, at any time, the opportunity to object, requesting the deletion of the own account from the list of those to whom they are addressed the above messages.
35) Personal data collected will not be used for purposes other than those specified in this Policy or any other rule of law.
36) At the request of the competent authorities, LOEM will provide information in its possession to enable the identification of the "Users", in order to detect and prevent illegal activities.
Rights of Interested parties
37) "Users" have the right to exercise the rights under Art. 7 D. Decree 196/03, as following. At any time, by deleting your account, you can request the total removal of all data provided.
Article 7 (Right to Access Personal Data and Other Rights)
- You have the right to obtain the confirmation of the existence or not of your personal data, although they are not recorded yet and their communication in intelligible form.
You have the right to obtain information over:
- origin of personal data
- the purposes and methods of the treatment
- the logic applied in case of treatment with the aid of electronic instruments
- the identity of the owner, manager and the representative appointed under article 5, paragraph 2;
- the subjects or categories of persons to whom the personal data may be communicated or who can learn about them as appointed representative in the State, responsible or nominated.
- You have the right to obtain:
- the updating, rectification or, when interested, the integration of data;
- the cancellation, the transformation into anonymous form or the blocking of data processed unlawfully, including those that do not 'need to be kept for the purposes for which the data were collected or subsequently processed;
- the certification that the operations in letters a) and b) have been notified, also as regards their contents, to those to whom the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate to the protected right
- 4. You have the right to object, in whole or in part:
a) for legitimate reasons the processing of personal data, pertinent to the purpose of collection;
b) the processing of personal data for the purposes of sending advertising materials or for direct selling or for carrying out market surveys or commercial communication.
38) Inquiries concerning the processing of personal data may be forwarded to the holder of their treatment using the following e-mail: email@example.com.
"Users", took note of the above, expressly agree to processing, to the communication and dissemination of personal data concerning them, within the limits indicated in the statement written above, stating that they are aware of the rights recognised by the above Article. 7 D. Decree 196/03.