Data treatment policy

INFORMATION TO DATA SUBJECT (WEBSITE VISITORS)

Introduction

This information to data subject concerns the data processing processed in the website https://www.neuraltext.com/, by Atmos Media s.a.s. di Cappiello A. & Co., with headquarters in Corso Duca degli Abruzzi 81/bis, 10129, Turin (Italy) email address: humans@neuraltext.com (hereinafter the “Data Controller”), in compliance with current data protection regulations, Regulation (EU) 2016/679 (hereinafter, “GDPR”) included.

Identity and contacts of the Data Controller

The Data Controller is Atmos Media s.a.s. di Cappiello A. & Co.
Since the Data Controller is located in Italian territory, there is no need to appoint a representative.

Contact details of the data protection officer of the data protection

The Data Controller has appointed a data protection officer (DPO), which could be contacted at the same address of the Data Controller or, alternatively, at dpo@neuraltext.com

Methods of processing

Delete and disabling cookies

Since cookies are normal text files, they can be accessed using word processing programs. In any case it is possible to configure your browser in order to prevent it from treating cookies.
Delete/disable cookies with Firefox:
http://support.mozilla.com/it/kb/Eliminare%20i%20cookie.
Delete/disable cookies with Edge:
https://support.microsoft.com/it-it/help/4027947/windows-delete-cookies.
Delete/disable cookies with Chrome:
http://support.google.com/chrome/bin/answer.py?hl=it&answer=95647.

Data provided voluntarily by the data subject

The data optionally and freely provided by the data subject, by sending e-mails to the addresses found on the site, may be acquired for purposes that will be specified each time.
In particular, in addition to the email address required to reply to the sender, any other personal data contained in the related communication will be processed. The interested party is invited to not enter special category data (for example data concerning their health) in the communications that will be sent to the Data Controller.
The data collected in this way will be stored and processed exclusively for the purpose of storing the correspondence and replying to the data subject. They will not be used for other purposes.

Purpose of processing and legal basis of processing

In relation to cookies of technical nature referred to in point 4) and to navigation data, the processing of the data subject’s personal data is carried out in order to enable proper browsing the site www.neuraltext.com. In this case the legitimate interest of the data controller is the legal basis of the processing.
In relation to the non-technical cookies referred to in point 4), the processing of personal data carried out through them allows us to offer a personalized browsing experience through profiling. In the latter case, the express consent of the interested party constitutes a legal basis.
In relation to data provided voluntarily by e-mail, the processing of personal data carried out makes it possible to reply to requests from the data subjects. The legitimate interest of the Data Controller in responding to the data subjects is the legal basis of the processing.

Modalities for providing the consent

The consent needed to allow data processing through non-technical cookies must be expressed through:
- by clicking on a specific box inside a banner.

The source of personal data

Only the data provided in the respect of the current information to data subject, collected by the website or by an email sent by the data subject.
The data resulting from public available sources will not be processed.

The recipients and eventual categories of recipients of personal data

The recipients of personal data may be:
- communication companies that carry out commercial communication and profiling activities on behalf of the Data Controller and are data processors;
- companies that offer services of an information society, including, in particular, those offering hosting services.

Categories of data

The data subject’s personal data will be processed. In any case, particular data (e.g.: data related to the state of health of a person, ex art . 9 GDPR) shall not be processed.

Data transfer

The Data Controller may intend to transfer personal data to a third country or to an international organisation. Such subjects may be:
- Communications companies, which carry out communication activities on behalf of the Data Controller;
- Companies that offer services related to the information society, including, in particular, those that offer hosting services;
- Communication service providers;
The transfer of personal data to such subjects, if they are established in another country or are an international organization, will be carried out only if it is considered adequate by the European Commission, which will verify that the other country, the area or one or more specific sectors within the other country or the international organization in question can guarantee an adequate level of protection of the Data Controller’s rights. In any case, the Data Controller – if they deem it necessary – reserves the right to reach specific separate agreements that will oblige these subjects to adopt adequate security and organizational measures, aimed at appropriately guaranteeing the Data Controller’s rights. Google Inc., in particular, is contractually bound to ensure appropriate protection of the Data Controller’s rights. The data can be transferred to the following countries: United States of America. To obtain a copy of this data or information about the place where it was made available, simply send a request to this address: humans@neuraltext.com

Personal data retention period

Personal data processed and stored for all the purposes referred to in this statement are processed and stored for a period not exceeding 12 months starting from the date of the single collection;
The Data Controller reserves itself the right, in any case, to request to the data subjectsto renew their consent to the processing and / or to verify the consents already expressed.

Optional nature of consent and consequences in case of lack of consent

In relation to personal data processed through technical cookies, in order to allow proper use of the web app, the communication of personal data is not a contractual obligation in relation to technical cookies, but is based on the legitimate interest of the data controller, since a fully functional web app could not be made available without this treatment. However, it is considered optional in relation to non-technical cookies. In the latter case, the failure to communicate such data will only determine the impossibility of providing a personalized service.
In relation to data provided voluntarily by e-mail, the processing of personal data is not a contractual obligation, but a treatment based on the legitimate interest of the Data Controller to reply to data subjects; without this treatment it would not be possible to reply to requests made by the data subject.

Rights of the data subject

Right to object
The data subject has the right to oppose, at any time and for reasons connected with their particular situation, to the processing of personal data concerning him/her, pursuant to Article 6, paragraph ,1 letters e) or f) of the GDPR, including profiling on the basis of these provisions. The Data Controller will refrain from further processing personal data, unless they are able to demonstrate the existence of compelling legitimate reasons for proceeding with the processing, which prevail over the interests, rights and freedoms of the data subject, or if they need to assess, exercise or defend one of their rights in court.
Other rights
- Right of the data subject to access data:
the data subject has the right to obtain confirmation from the Data Controller of whether or not their personal data is being processed at that time and, in that case, to obtain access to their personal data and to specific information, in accordance with Article 15 of the GDPR;
- Right of rectification: the data subject has the right to obtain the correction of inaccurate personal data concerning them from the Data Controller, without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, and to provide an additional declaration, in compliance with article 16 of the GDPR;
- Right to delete data, including the right to withdraw consent: the data subject has the right to obtain the deletion of personal data concerning them by the Data Controller, without undue delay, and the Data Controller is obliged to cancel the data without undue delay; the data subject also has the right to withdraw his consent, if the reasons set out in article 17 of the GDPR apply; in this case, the right of revocation can be exercised at any time without undermining the lawfulness of the treatment based on the consent given prior to the revocation;
- Right to limit processing: the data subject has the right to obtain a limitation of the processing from the Data Controller, when the hypotheses defined by article 18 of the GDPR apply;
- Right to data portability: the data subject has the right to receive, in a format which is structured, in common use and can be read on an automatic device, the personal data concerning him/her that were provided to the Data Controller, and has the right to transmit this data to another data controller without impediment by the Data Controller, in the cases and under the conditions specified by article 20 of the GDPR.

Exercise of the rights

The request to exercise the rights outlined in this information to data subject, included, in particular, the right to delete data and to withdraw consent, must be addressed directly to the Data Controller at the email address Alternatively, you can exercise your rights by sending a communication via registered letter to the following address: Corso Duca degli Abruzzi 81/bis, 10129 Turin (Italy).

Accessibility of the information to data subject

The information to data subject is accessible at the address Corso Duca degli Abruzzi 81/bis, 10129 Turin (Italy). If expressly requested by the data subject, the information may also be orally provided, provided that the identity of the data subject is proven, by means of a telephone call.