ACCORDING TO EU 2016/679 (GDPR) LAW AND 196/03 DECREE (AND SUBSEQUENT MODIFICATIONS AND INTEGRATIONS)
Last updated: December 14th, 2021
By using the Websites and services offered through the platforms distributed by The Digital Box, you give your consent that all personal data that you submit may be processed by us in the manner described in this Privacy Notice. If you do not agree to these terms, you are not authorized to use any services.
- Important information
We may use different and specific privacy policies for each of the products, services, tools offered and/or used by The Digital Box.
1.2. Contact us
Data controller: the natural or legal person, public authority and any other authority, association or entity responsible, also together with another owner, for the decisions regarding the purposes, the methods for processing personal data and the tools used, including the security profile. In this specific case, the Data controller is The Digital Box SpA headquartered in Largo San Francesco, 5 – 70024 Gravina in Puglia (BA) email@example.com.
Data processor: the person, company, authority, association or entity which processes personal data on behalf of the controller; they are appointed according to their professional qualities and their knowledge of law and practice in terms of data protection.
Data Protection Officer or DPO: appointed by the controller or owner, he is responsible to observe, evaluate and organize the management of the processing of personal data (and therefore their protection) within a company, in compliance with European and national privacy regulations.
Customer or Company: The Digital Box customers, its Licensee Partners and/or Resellers that represent substantially the “ADA” platform users.
End-User or Interested Person: With these terms we refer to people browsing one of the websites of The Digital Box, use a The Digital Box APP, people contacted or people inserting data through one of the platforms developed and managed by The Digital Box, i.e. «ADA».
Licensee Partners and Resellers: The Digital Box business partners that sell digital marketing products to «customers» and can also be controlled by The Digital Box SpA.
ADA: The digital marketing platform developed and managed by The Digital Box.
ChatBot: Chat bot, chatbot or chatterbot, is a software designed to simulate a conversation with a human being. The main purpose of this software is to emulate human behavior and is used for various purposes such as an online guide to answer FAQs by users accessing a site etc. The Digital Box could offer, within its web spaces, the possibility, for end-users and customers, to interact with a chatbot for executing the existing contract or improving the experience.
Websites: The websites managed by The Digital Box such as www.thedigitalbox.com and www.adaoncloud.com and www.digitalconvergenceday.com
Personal Data: We consider personal any information sent voluntarily that personally identifies someone, including contact information such as name, e-mail address, company name, address, phone number and other information about you or your business. Personal information may also include information on transactions, both free and paid, information available on the Internet, as per
Facebook, LinkedIn, Twitter and Google, or publicly available information.
We also consider very important personal data: credit or debit card numbers, account information, financial, social security references, passport numbers or other identity documents.
Sensitive Data: We consider sensitive data, information pertaining to: racial or ethnic origin, conditions or information on physical or mental health, financial and judicial information.
Browsing Information: It refers to information on your computer and visits to this website (and others The Digital Box websites) such as the IP address, the geographical location, the type of browser, the source, the duration of the visit and the pages viewed.
Consent: It refers to the free expression of will of the subject that explicitly agrees to the processing of their personal/sensitive data, for which they were previously informed by the Data Controller
Free Trial: This refers to a «trial» or demo version of ADA (or of another web app provided by the Owner) which allows users to try out the platform without purchasing it immediately, with the intention of making them understand the potential and technical features of the product.
- How The Digital Box and our customers use the services of the digital marketing platforms
3.1. ADA platform Services
The services marketed by The Digital Box, its Licensee Partners and related Resellers, allow any company that purchases an account on the ADA platform to create web pages for marketing purposes using our servers. Through these pages, visitors (end users) can learn more about companies, download content and provide data, contact information and other demographic information. This information, which is stored and managed on servers of our service providers, are then used so that visitors can be contacted according to their interest in goods or services of the company and interact with the company itself.
3.2. How The Digital Box uses ADA
3.3. How our customers use ADA
The agreements and contracts with our customers (companies) that use the ADA platform services prohibit us from using the data collected, except as necessary to provide and improve the services offered by the platform itself, as allowed
The Digital Box offers the ADA platform services to allow the collection of information under the responsibility of its own customers (companies) and does not have direct relationships with people (end users) whose personal information is processed. If you are a customer (end user) of one of our customers (companies) and no longer wish to be contacted by a company that uses the services
of the ADA platform provided by The Digital Box, contact the company you interact with directly. We also inform you that we may transfer personal information to companies that help us to provide our service and which we have provided to appoint data controllers who operate under our control.
- Data collected
4.1. While visiting our websites
You are free to explore the websites without providing any personal information about yourself. When you visit the websites or register for allowing your company to use the subscription services of our platforms (such as ADA), we may ask you to provide your personal information and we will collect our websites browsing information.
4.2. While using our mobile application
We use mobile data analysis software to allow us to better understand the functionality of our apps on your mobile device. This software can record information such as the frequency with which the application is used, the events that occur within the application, the aggregate use, performance data and where the application was downloaded. In addition to the information that we collect on our websites, when using our mobile apps, we may also collect and memorize your geographical location, model and device version, device ID, device operating system version and ADA account credentials.
We send push notifications from time to time in order to update you on events or promotions. If you no longer wish to receive such communications, you can deactivate them at the device level.
We may link the information we store in the analysis software to the personal information sent in the mobile app. We do this to improve the services we offer you and improve our marketing, analysis and site features.
4.3. When you request information and subscribe to the newsletter
When you ask for more information about our platforms or our company via contact form, email, specific landing page, or you ask to subscribe to our newsletter (periodic sending of information on our company, including promotional content), we may ask you for some data such as name, surname, job title, telephone, email, etc.; Such information will be used exclusively for the purposes that will be specified from time to time, including pre-contractual purposes.
In the case of requests that include an online demonstration of one of our platforms, we may ask for your consent to record it (video and audio) for the sole purpose of assessing the quality of the service provided.
4.4. Information on minors
The Digital Box websites and services offered through the ADA platform are not intended for children under the age of 16 nor do we knowingly or intentionally collect information on children under the age of 16. If you believe that, for reasons not known to us, information on children under 16 has been improperly collected and without parental consent, please contact us at firstname.lastname@example.org, in order to allow us to intervene in this regard.
- How we use the data we collect
Data transfer abroad: the data collected will not be transferred abroad.
5.2. We never sell personal data
The Digital Box will not sell/disclose in any case your personal information to third parties nor will it be disseminated.
5.3. End users and Customers’ personal data
- improving the browsing experience by personalizing websites and improving the ADA platform;
- collecting and processing statistical information on our platforms and websites’ users, but this information will not be used to identify individual users without explicit consent.
(c) If you have given your explicit consent, you may be contacted by companies for marketing purposes.
(d) If you have given your specific consent, you can be profiled for marketing purposes to allow companies to propose specific offers dedicated exclusively to you.
(e) If you have subscribed to a «Free Trial», we may carry out soft opt-in activities, i.e. direct marketing via e-mail, to check what you think of our digital marketing platforms and offer you services similar to those already subscribed to or purchased, unless you expressly refuse to receive such communications, which may be expressed at any time. It should be noted that the processing of personal data for this purpose is a legitimate treatment under Art. 130, co. 4 of the Privacy Code, which does not require the consent of the person concerned, provided that the services are similar to those covered by the current contract and that the person concerned, adequately informed, does not refuse such use, initially or in subsequent communications. This means that the interested party may object to the processing of personal data for this purpose at any time, even during communications from the Owner, by writing to the addresses listed in the «Contact» section of this statement, as well as using the link at the bottom of the communications received by email.
Furthermore, companies that use the ADA platform for the purposes envisaged and contracted, are allowed to collect, behind specific end user consent, including sensitive data that is processed and stored in compliance with the principles of confidentiality and lawfulness of the treatment.
As for the data collected through the ADA subscription services (therefore of the companies), these are treated for the following purposes:
- provide the subscription service (which may include the identification, prevention and resolution of technical and safety issues);
- respond to requests for technical assistance;
- fulfill the obligations set forth in the Terms of Service.
5.4. Service providers
We employ other companies and individuals to provide services to visitors to our websites, our digital marketing platform (ADA) and subscription services. Examples may include data analysis, marketing assistance, the issue of tax documents, the processing of information provided by end-users for improving the service,
5.5. Personal data security
We use a variety of security technologies and procedures to protect your personal information from unauthorized access, use or disclosure. We protect personal information stored on servers and computers in a controlled and secure environment, protected from unauthorized access, use or disclosure. When sensitive personal information (such as geo-location data) is collected on our websites and / or transmitted to other websites, it is protected through the use of cryptography, such as the Secure Socket Layer (SSL) protocol.
If you have questions about the security of your personal information, you can contact us via email at email@example.com.
5.6. Social Media features
Our websites and the ADA platform include social media features, such as the «Like» button on Facebook, the
«Share» button etc. These features can collect your IP address, the page you are visiting on our sites and set a cookie
5.7. External websites
5.7.1 Interaction with social networks and other external platforms
The services offered through the ADA platform allow interaction with social networks or other external platforms, even directly from the site pages. The interactions and the information acquired are in any case subject to the privacy settings that the end-user (interested) has prepared and accepted in relation to each social network.
In the case where an interaction service with social networks installed, it is possible that, even if the end-users do not use the service, the same collect traffic data relating to the pages in which it is installed.
To find out the personal data collected, the location of treatment and all the details, you can consult the privacy policies of the social networks involved, always identifiable by specific logo or wording on the site pages. The privacy policies of some of the main related services are indicated at the bottom of this Page.
5.8. Storage of personal data
We keep the personal information of our customers (companies) as long as we believe they are potentially useful to allow the necessary contacts for subscription services that have been purchased on ADA or, if necessary, to comply with our legal obligations, resolve disputes and enforce our agreements. At the end of the treatment period and at the conclusion of the contract, we will securely remove all relevant data in accordance with the contractual conditions between The Digital Box and companies.
If, as an end-user / interested party, you provide information to our customers (companies) to keep in touch with them or use of the services offered by them, our customers will decide how long to keep the personal information they
collect from you. In any case, The Digital Box, internally and for commercialized platforms, applies rules that they prevent data retention for an indefinite period and therefore limit the storage time in compliance with the principle to minimize data processing. If one of our customers (company) stops using the subscription service with ADA, we will provide the customer with access to all stored information, including personal information provided by end users, in an exportable format. In the case of early contractual termination, we could, without legal limits, eliminate all of the end-user information.
5.9. Forced disclosure
We reserve the right to use or disclose personal information if required by law or if The Digital Box should believe that the use or disclosure is necessary to protect its rights, protect the security of end-users or the safety of others, to allow investigations on fraud or to comply with a law.
- Browsing information
In order to protect its web pages visitors, The Digital Box uses a special script to ensure the proper management, ex lege, of consent relating to cookies. Within the page dedicated to Cookies, the interested party can find details about the cookies used and the relative indications for the modification of the consent provided. The Owner remains in any case available to provide any further information on the subject.
6.2. Browsing information collected by our customers (companies)
ADA customers (companies) may use tools provided by third parties to collect browsing information when visiting their web pages managed through our digital platforms. The Digital Box does not control the use of these tools by our customers (companies), nor does it control the information they collect or how they use it.
6.3. Single Sign-On
To access our web pages and/or platforms we could use a Single Sign-on (SSO) service like your Google account. This service will authenticate your identity and provide you with the opportunity to share some personal information with us such as your name and e-mail address to complete our registration form. Such services could offer the possibility to publish information about your activities on this website on your profile page and share them with others within your network.
- Data subjects’ rights
7.1. Revision, correction and removal of personal data
Upon request, The Digital Box will provide you with information on the possession of any of your personal information. By providing us with your personal data, you have the right to:
- Know what information you gave us;
- Change/update/correct the information provided;
- Request to not use the information provided to contact you;
- Request for the information provided to be removed from any of our database;
- Request for your user data to be permanently deleted from our archives;
- Refuse to be solicited by The Digital Box or third parties;
To exercise one of these rights, please contact us via email at: firstname.lastname@example.org or by writing to The Digital Box Largo San Francesco, 5 – 70024 Gravina in Puglia (BA) Italy, For the Attention of: Privacy Office. We will respond to your request within a reasonable period of time and inform you on the actions taken.
If you are an end-user, you have the same rights as above and you can exercise them by contacting the companies you have given consent for your data processing.
Furthermore, it is important for you to know that if you believe that the processing of your personal data violates the data protection law or your right to data protection has been damaged in any other way, you can contact the competent authority. In Italy it is the Privacy Guarantor (link: https://tinyurl.com/y53c4ye2).
7.2. Anti-spam policy
Any commercial communication sent without the recipient’s consent is spam. The use of the services offered by The Digital Box is intended for the sole and exclusive purpose of sending messages to recipients who have accepted and confirmed that they wish to receive communications. No other commercial use is accepted and permitted. Among the non-commercial uses of the ADA Service, it is granted that referred to, for example, the sending of transactional messages to individual recipients with whom a relationship has been established. We require all our customers to agree and adhere to the no-spam policy, and any violations of the usage rules of The Digital Box platforms could lead to the suspension or termination of subscription services.
7.3. Unsubscribe from our communications
If you are subscribed to one of our newsletters, you can unsubscribe from our marketing communications by clicking on the link «Delete» located at the bottom of our e-mails or by sending an email to email@example.com or sending mail to The Digital Box Largo San Francesco, 5 – 70024 Gravina in Puglia (BA) Italy, For the Attention of: Privacy
7.4. Unsubscribe from the communications of our customers
Our customers (companies), who use digital marketing services from The Digital Box, are solely responsible for their own marketing emails and other communications; we cannot cancel you from their communications. You can unsubscribe to marketing communications of our customers by clicking on the «cancel» link located at the bottom of the email or by contacting them directly.
7.5. Data Protection Officer
The owner has appointed the Data Protection Officer: Findata Srl who can be contacted at the following mailbox firstname.lastname@example.org