Flyer Tech s.r.l., with registered office at Via Antichi Pastifici 8/A – Molfetta (BA) – 70056, VAT number 03494761202, email: info@transactionale.com, pec: flyertechsrl@legalmail.it (hereinafter, the “Data Controller”), in its capacity as Data Controller of personal data pursuant to articles 4, n.7) and 24 of EU Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data (hereinafter, the “Regulation”), informs, pursuant to articles 13 and 14 of the regulation, that it will process personal data relating to users of the website https://www.marlene.live/.

1. Purpose of the processing (what data we process)

In accordance with the European Regulation on the protection of personal data, legal entities cannot be considered data subjects and therefore the European Regulation does not apply. However, if personal data referring to an individual are inserted in the context of the collection of corporate data, this will be considered a data subject within the meaning of the aforementioned Regulation.

CONTACT US: If you fill out the contact form, we will ask you to provide your personal data (name and surname), company name, email address, and phone number.

LIVE STREAMING SCHOOL: To receive updates, it is necessary to fill out the dedicated form with your personal data (name and surname), email address, specify your occupation, and the company you work for.

DOWNLOAD THE GUIDE: To receive the Livestream Shopping guide, we will ask you for personal data (name and surname), company name, email, and phone number. In any case, IP address and browsing data will be collected.

2. Legal Basis and Purposes of Processing

The processing of data will be carried out to allow the performance of activities related to the establishment and management of the service requested by the controller. The provision of data is mandatory in all cases where the legal basis is the execution of the contract or the fulfillment of legal obligations arising from the purchase, while it is optional in all other cases; in any case, failure to provide it will not make it possible to process the requests. The data will be processed lawfully, fairly, and with the utmost confidentiality, in compliance with the appropriate security measures as provided by the Code and the Regulation. The processing will be carried out by analogical/digital means. The data will not be subject to public disclosure. In particular:

CONTACT US: The legal basis is consent, and your data will be processed to allow us to respond to your requests.

LIVE STREAMING SCHOOL: The legal basis is the execution of pre-contractual measures carried out at the request of the data subject, and your data will be processed to allow us to send you the requested information.

DOWNLOAD THE GUIDE: The legal basis is the execution of pre-contractual measures carried out at the request of the data subject, and your data will be processed to allow us to send you the ebook.

IP address and browsing logs: we will process the data on the legitimate interest of the company and compliance with legal obligations.

3. Processing Methods – and Data Retention Period

The data controller will process personal data for the time necessary to fulfill the purposes set out above and in any case for:

CONTACT US: the data will be used to respond to your requests and will then be deleted. The verification regarding the obsolescence of the data is carried out every 12 months.

LIVE STREAMING SCHOOL: the data will be used to send you information about the school and will then be deleted. The verification regarding the obsolescence of the data is carried out every 12 months.

DOWNLOAD THE GUIDE: the data will be used to send you the guide and will then be deleted. The verification regarding the obsolescence of the data is carried out every 12 months.

4. Data Communication

The Data Controller may communicate the data for the purposes referred to in article 2 to all subjects to whom communication is mandatory by law for the performance of purposes provided for by law. The data will not, however, be subject to public disclosure.

5. Place of Storage and Transfer of Data

The management and storage of personal data will take place on servers located within the European Union of the Data Controller and/or of third-party companies duly appointed as Data Processors. Currently, the servers are located in Europe. For the sending of commercial information, the Data Controller also uses a provider that transfers data to countries outside the EU. The Data Controller hereby ensures that the transfer of data outside the EU will take place in compliance with the applicable legal provisions by stipulating, if necessary, agreements that guarantee an adequate level of protection and/or by adopting the standard contractual clauses provided by the European Commission. The list of data processors is available at the registered office.

6. Data Subject Rights

The user, as a data subject, has the rights referred to in article 15 of the Regulation, namely:

1. The data subject has the right to obtain confirmation as to whether or not personal data concerning him/her are being processed, even if not yet recorded, and their communication in intelligible form.

2. The data subject has the right to obtain indication:

a) of the origin of personal data;

b) of the purposes and methods of processing;

c) of the logic applied in the case of processing carried out with the aid of electronic instruments;

d) of the identifying details of the controller, processors, and representative;

e) of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it as designated representative in the territory of the State, processors or persons in charge.

3. The data subject has the right to obtain:

a) updating, rectification, or, when interested, integration of data;

b) the deletion, transformation into anonymous form, or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;

c) certification that the operations referred to in letters a) and b) have been brought to the attention, including their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right.

4. The data subject has the right to object, in whole or in part:

a) for legitimate reasons, to the processing of personal data concerning him/her, even if pertinent to the purpose of the collection;

b) to the processing of personal data concerning him/her for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication.

Also pursuant to articles 15 and following of the GDPR, the user has the right to request access to his/her personal data at any time, their rectification or deletion, limitation of processing in cases provided for by article 18 of the GDPR, to obtain in a structured, commonly used, and machine-readable format the data concerning him/her, in cases provided for by article 20 of the GDPR. At any time, the user can revoke, pursuant to article 7 of the GDPR, the consent given; lodge a complaint with the competent supervisory authority pursuant to article 77 of the GDPR if he/she believes that the processing of his/her data is contrary to the legislation in force.

The user may submit a request for opposition to the processing of his/her personal data pursuant to article 21 of the GDPR in which he/she provides evidence of the reasons justifying the opposition: the Data Controller reserves the right to evaluate the request, which would not be accepted in case of compelling legitimate reasons for processing that prevail over the interests, rights, and freedoms of the user.

The data subject may exercise the rights referred to in the preceding article at any time by sending:

– a registered letter with acknowledgment of receipt to: Flyer Tech s.r.l., Via Antichi Pastifici 8/A – Molfetta (BA) – 70056

– an email to the address: info@transactionale.com

– pec to the address pec: flyertechsrl@legalmail.it

7. Data Controller, DPO

The Data Controller of the processing is Flyer Tech s.r.l., whose contact details are indicated at the beginning of the document. The data controller informs that he has appointed Lawyer Antonino Polimeni (tax code PLMNNN78T04F158Z) as the Data Protection Officer, who can be contacted at the following address: dpo@transactionale.com

8. COOKIES

Regarding the cookies that are installed on your machine, we inform you that providing the data is optional. However, some cookies are necessary to allow correct navigation on the website and therefore, without consent, the website may not function. This information on the use of cookies on this website is provided to the user in implementation of the provision of the Guarantor for the protection of personal data of 8 May 2014 “Identification of simplified methods for the information and acquisition of consent for the use of cookies”, the guidelines on the use of cookies and other tracking tools of 10 June 2021, and in compliance with article 13 of the GDPR.

HOW MANY TYPES OF COOKIES ARE THERE?

TECHNICAL COOKIES

These are generally necessary for the correct functioning of the website and to allow navigation; without them, you may not be able to correctly view the pages or use some services. For example, a technical cookie is essential to keep the user logged in during the entire visit to a website or to store language settings, display settings, etc. They are not used for any further purposes and are normally installed directly by the website owner or manager. The installation of such cookies does not require the prior consent of users. These cookies are divided into:

a. Essential cookies, strictly necessary for the operation of the Site. Without the use of such cookies, some parts of the Site would not work. They include, for example, cookies that allow access to protected areas of the Site. These cookies do not collect information for marketing purposes and cannot be disabled;

b. Session cookies, which are deleted immediately when the browsing session is closed;

c. Persistent cookies, which – unlike session cookies – remain within the browser for a certain period of time. They are used, for example, to recognize the device connecting to the site, facilitating authentication operations for the user;

d. Analytical cookies, assimilated to technical cookies where used directly by the site manager to collect information, in aggregate form, on the number of users and how they visit the site;

e. Functionality cookies, which allow the user to navigate based on a series of selected criteria (e.g., language, products selected for purchase) in order to improve the service provided to the user.

PROFILING COOKIES

These cookies are intended to profile the user and are used to send advertising messages in line with the preferences expressed by the user during his/her browsing. This website does not use first-party profiling cookies, but only third-party profiling cookies, which will be dealt with in the following paragraph.

THIRD-PARTY COOKIES

They are generated and managed by subjects other than the website owner on which the user is browsing (usually by virtue of a contract between the owner of the website and the third party).

In particular, the website uses the following cookies: