Privacy policy

EFFECTIVE April 20, 2020

SOUNDREEF MEDIA SERVICE

Privacy policy

The present privacy policy is provided, in accordance with the Article 13 of the Regulation 2016/679 (hereinafter, “GDPR”) and the Code on personal data protection, D.lgs 196/2003 (hereinafter “Code”), by SOUNDREEF MEDIA SERVICE (henceforth, for brevity “SMS”), with registered office, in Via del Lauro, 14 – 20121 Milan,- www.soundreefmediaservice.com, such as data controller and for all the purposes of processing, that are described after.

In this policy we will explain to you the purpose and the way in which SMS collects and processes your personal data, which categories of data are processed, what are your rights as a data controller and how they can be exercised.

Before giving any personal information, we invite you to read this privacy policy carefully.

We inform you that the present privacy policy could be subject of some updates in future, in compliance with national and European legislation; therefore, we invite you to check this page constantly in order to know any modifications.  

Categories of personal data.

The Web site offers informative and illustrative contents. During the browsing activities, it’s possible to collect some visitor’s information, in the following ways:

1. Navigational information (browsing data)

The computer systems and software used by the site, acquire certain personal data in the normal course of the service, which is implicit to be able to use the Internet communications protocols.

This category of data includes: IP addresses, the type of browser used, the operating system, the domain name and addresses of websites from which access or exit has been made, information about the pages visited by users within the Site, the time d’ access, the permanence on the single page, the analysis of internal path and other relative parameters to the operating system and the computer environment of the user.

2. Data collected using cookies or similar technologies

The eventual use of cookies – or other tracking tools- by SMS or third party service providers used by SMS,  is carried out with the aims to offer you the best navigation experience, as well as other purposes described in this document and in the Cookie Policy, at this link https://www.soundreefms.com/it/informativa-sui-cookie/.

3. Data provided by the user for the subscription to the newsletter service

If you subscribe to the newsletter service, filling the specific form, you will be asked to provide an e-mail address. At the end of the procedure, you will receive a message to the email address indicated to confirm your registration. No further personal information is required.

4. Data provided by the user at the time of activation of the account and/or during the call with operator

In order to register and/or access to reserved area of the Site, to receive and/or to request any information by message at SMS’s e-mail addresses or SMS customer service, you will be asked for example to provide some personal data, such as your name, an email address, the address of your website.

Any other information you provide in the free field of the contact form and/or to the operator during the call, considered useful for the purpose of your request, will be treated according to the principles of fairness, transparency and relevance, in accordance with this privacy policy, the Privacy Code rules and the GDPR.

If, personal data of third parties are provided, this will be under your sole responsibility, ensuring that you have the right to communicate or disseminate it, freeing the Controller and its supplier for any consequence and liability to aforementioned third parties.

The Data Controller will not collect sensitive data or belonging to the particular categories referred to the Article 9 of Regulation (EU) 2016/679 or data relating to criminal convictions or offences.

5. Data provided for the purchase of services offered through the website

If SMS services are purchased though the Website, SMS could collect, among the other, the following categories of information:

• Name, surname, date and place of birth, tax number and/or VAT number;
• Residence address, telephone number and e-mail address;
• Registered office and registration number in the Chamber of Commerce of the company or business;
• Certified email address;
• Credit card details, bank and/or postal details for the payment of the service purchased.

The provision of the personal data indicated is necessary to enable the establishment and continuation of the contract and to enable SMS to provide services in accordance with the service requested.

Processing place and method

The processing of personal data will take place at the office of SMS or in any case within the European Union and/or at the servers of third companies in charge and duly appointed as Data Controllers.

The processing is carried out using computer, telematic and paper means, with organizational methods and logic strictly related to the stated purposes.

Processing purposes and legal basis

The above personal data will be processed by SMS exclusively for the purposes and within the following limits.

1. For the establishment and performance of a contract

The personal data you have provided for the purchase of SMS services will be processed for the establishment and execution of the contractual relationship and to provide assistance in relation to the services you have purchased.

For that purpose, SMS will process the personal data referred to the point 5.

The data you provided for your subscription to the newsletter service, in the contact form or during the call to customer service, will be processed to provide the service and/or perform the requested operations.

The provision of such data is necessary. In their absence, you will not be able to provide the service and/or perform the necessary operations to what you request.

Besides, SMS informs you that such data may be used both to send you communications relating to the specific service purchased and/or to the operations necessary to secure the requested service, and to inform you about the other services offered and initiatives by SMS.

If you’re not interested in receiving any further information about other services or initiatives of SMS, you can notify us following the indication at the bottom to every single e-mail.

1. For compliance with a legal obligation

Your personal data may be processed by SMS for the compliance with a legal obligation incumbent upon it such as, for example, related to the performance of the contractual relationship between us in being (electronic invoicing). By way of illustration, your data will be processed to carry out tax obligations, current account debits and anything else necessary in relation to the contractual relationship resulting from the purchase of a service.

For these purposes, SMS may process your personal data, residence data, the registered office of the company or business, tax number and/or VAT number.

1. For the purposes of the legitimate interests pursued by SMS

The personal data provided by you, if necessary, will be processed by SMS in order to comply with the legal obligations imposed on it, in relation to the specific circumstances of the case, and for the exercise of a right or to safeguard a right to SMS or third parties.

1. Based on your consent

If you give us your consent, SMS can analyze and collect data related to your experience of use of the Site, products, services and use of our content as explained more widely in our Cookie policy available at the following link

https://www.soundreefms.com/it/informativa-sui-cookie/.

In this case consent is optional and can always be revoked by exercising the options explained and, in the manner, indicated in our cookie policy.

Categories of subjects to whom personal data can be communicated and purposes of communication

SMS may communicate, for the same purposes, some of your personal data also to third parties, of which it relies for the performance of activities related to the management and for the exact execution of the contractual relationship. In particular, your data can be communicated to external companies that offer administrative and logistic services to SMS and external consultants. These companies will process your personal data as Data processors, in accordance with art.28 of the Regulation.

Moreover, SMS can communicate your data, in addition to those to whom the communication is due by virtue of legal obligations, to Public Administrations, to provident and assistance institutions, credit institutions with which SMS operates for payment purposes, members of the Board of Directors and the Board of Statutory Auditors, designated by SMS, for the purpose of carrying out their institutional tasks and functions.

The list of Data Processors is at your disposal at the SMS office and can also be requested by email by writing to info@soundreefms.com.

There is no other form of dissemination of your data to indeterminate subjects.

Period of storage

The personal data provided for the purchase of a service will be kept for as long as necessary for the performance of the contract and in any case for a further period of 12 years after the termination of the relationship exclusively for purposes related to the compliance of obligations law or the defense of SMS rights in court.

The data collected according to the provision of consent and for the subscription to the newsletter service will be kept until the withdrawal of the same or the unsubscription’s request for from the service according to the modalities of time indicated.

The personal data provided for the activation of an account will be kept until it is deactivated in the manner indicated from time to time.

The personal data collected to provide you with assistance or information will be kept for as long as necessary for the execution of the operations and/or services requested and, in any case up to 3 months after the conclusion of the operation and/or services.

The data collected during navigation will be deleted according to the law and indicated in the cookie information, available at the link https://www.soundreefms.com/it/informativa-sui-cookie/.

On expiry, the data will be automatically deleted or made permanently anonymous. Therefore, upon expiry of the retention period, the right of access, erasure, rectification and the right to data portability may no longer be exercised

In any case, SMS may retain some of your personal data if it proves necessary to defend or enforce a right of the same or to fulfill a legal obligation.

Data subjects’ rights

We inform you that, in accordance with current regulations, you can:

request and obtain information about the existence of your personal data at SMS and about the processing of data put in place by SMS and to obtain access to such data;

request and obtain the reception in a structured format, in common use and readable from automatic device of the personal data supplied to SMS, which are processed by automated means;

ask and obtain the modification and/or correction of your personal data if you believe that they are inaccurate or incomplete;

request and obtain the erasure – and/or limitation of the processing –of your personal data in the case of data or information not necessary –or no longer necessary – for the purposes preceding or if you revoke the consent on which the processing is based, provided that there is no other legal obligation to process them;

exercise the right to object to processing and/or to automated decision-making processes at any time to the data at any time, unless we have legitimate reasons to proceed with processing.

Requests for your rights may be addressed to SMS info@soundreefms.com.

Finally, we inform you that, in accordance with current regulations, you can make any complaints regarding the processing of your personal data to the Data Protection Supervisor. More information is available on the Site www. www.garanteprivacy.it.

Milan, 20.04.2020