PRIVACY POLICY
I - INFORMATION RELATING TO THE WEBSITE PRIVACY POLICY
1. This section provides the users with information concerning the management methods of the https://writeapp.io website used for the processing of users’ data.
2. This information is provided to those who interact with StreetLib, at: https://writeapp.io pursuant to art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and the Italian legislation in force for the protection of personal data, d.lgs. 196/2003 and subsequent amendments, in particular those introduced by d.lgs. 101/2018.
3. The information is provided only for https://writeapp.io and not for other websites that may be consulted by the user through links contained therein.
4. The purpose of this document is to provide guidance on the manner, timing and nature of the information that the data controller must provide to the users of the https://writeapp.io web page, regardless of the purpose of the connection, according to the Italian and the European legislation.
5. The information may be subject to changes due to the introduction of new rules in this regard, we therefore invite the user to periodically check this page.
6. If the user is under 16, pursuant to art. 8, par. 1 EU Regulation 2016/679, must show his consent through parental permission.
II - DATA PROCESSING
Data Controller
1. The controller shall be the natural or legal person, public authority, service or other body who, individually or together with others, determines the purposes and means of processing of personal data. He also deals with data security profiles.
2. With regard to this website https://writeapp.io the data controller is: Streetlib S.r.l. at the headquarters of Corso Venezia 10, 20121, Milano (MI). For any clarification or exercise of rights, the users can contact him at the following email address: info@streetlib.com
Data Processor
1. The processor shall be the natural or legal person, public authority, service or other body who processes personal data on behalf of the controller.
2. Pursuant to Article 28 of EU Regulation N. 2016/679, the data controller has appointed as data processor for this website https://writeapp.io.
Data Protection Officer - DPO
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1. The data protection officer is provided for by art. 37 of EU Regulation no. 2016/679. He cooperates with the Data Protection Supervisor and he is the reference, also with respect to data subjects, for issues related to the processing of personal data (art. 38 and 39 of EU Regulation no. 2016/679) and he coordinates the implementation and maintenance of records of processing activities (art. 30 of EU Regulation no. 2016/679). 2. As required by art. 37 par. 7 of EU Regulation no. 2016/679, the email address of the Data Protection Officer is: dpo@streetlib.com
Place of data processing
1. The data will be processed within the European Union. In the event that Streetlib avails of services located in third countries, the company will check beforehand that they provide adequate safeguards approved by the European Commission and/or in compliance with the EU-U.S. Privacy Shield.
Communication of data to third parties
1. The data of the users acquired during the navigation on the website may be communicated to third parties, who, as data processor or anyway authorized to process, will process the personal data communicated on behalf of Streetlib.
2. Streetlib can communicate the data of the users acquired during the navigation on the website to: external technical advisor; cloud service providers; payment systems institutions; commercial partners dealing with the delivery of paper books.
III - COOKIES
Function of cookies
1. Cookies are small strings of text used to store certain information that may concern the user, his preferences or the Internet access device (computer, tablet or mobile) and may be used for different purposes. In particular, a cookie consists of a small set of data transferred to the user’s browser from a web server. They are not executable codes and they do not transmit viruses.
2. Cookies can be distinguished in first-party cookies if installed on the user’s browser by the operator of the website visited and third-party cookies if sent from websites or web servers other than the one visited by the user.
3. The https://writeapp.io website uses cookies to make the user’s browsing experience easier and more intuitive and to monitor the number of access to the website and the interactions of the user with the website for statistical purposes.
4. Cookies do not record any personal information and the data collected are not stored. If you wish, you can prevent the saving of some or all cookies. However, in this case the use of the website and the services offered may be compromised. To proceed without changing the options related to cookies, just continue browsing.
Cookies used
1. The website https://writeapp.io uses technical cookies, analytical cookies and third party profiling cookies:
a) Technical cookies
1. Technical cookies are installed in the user’s browser and are used for navigation purposes and to facilitate access to and use of the website by the user. They are necessary for the transmission of communications over an electronic network or to provide the service requested by the customer. The use of technical cookies allows the safe and efficient use of the website.
2. Technical cookies are: navigation or session cookies, which ensure normal navigation and use of the website (allowing, for example, to make a purchase or to login to have access to reserved areas); functionality cookies, that allow the user to browse according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.
3. Technical cookies do not require the prior consent of the user to be installed.
b) Analytical cookies
1. The website https://writeapp.io uses Google Analytics and Facebook Pixel cookies. These cookies analyse the visitors’ traffic and monitor the number of access, for purely statistical purposes.
2. With regard to the installation of these cookies, the https://writeapp.io is a mere technical intermediary between the third party and the user, as it has no obligation to provide the user directly with the relevant information and to acquire consent to the installation of cookies, being the redirection to the updated link to the information and consent forms published by the third parties considered sufficient.
3. Below there are the links to the pages containing the extended information and the consent forms of the third parties, where the users may refuse their consent to the installation of cookies: - Google Analytics: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=it - Facebook Pixel: https://www.facebook.com/policies/cookies/
4. Google Analytics and Facebook Pixel cookies are used by our website for technical purposes. However, it cannot be excluded that Google and Facebook carry out user tracking activities. The user is invited to consult the extended information at the links above.
Rights of the user
1. The settings for managing or disabling cookies may vary depending on the Internet browser used. In any case, the user can manage or request the deactivation or deletion of cookies, by changing the settings of his internet browser. Such deactivation may slow down or prevent access to certain pages of the site and may remove the preferences that the user has set for the navigation on the website.
2. For further information and support it can also be visited the relevant page of the web browser currently used:
- Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
- Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences
- Safari: http://www.apple.com/legal/privacy/it/
- Chrome: https://support.google.com/accounts/answer/61416?hl=it
- Opera: http://www.opera.com/help/tutorials/security/cookies/
IV- THE DATA PROCESSED
Modalities of data processing
1. Like all websites, this site also uses log files, used to store the information collected automatically during users’ visits. The information collected can be the following:
- internet protocol (IP) address;
- type of browser and device parameters used to navigate on the site;
- name of the internet service provider (ISP),
- date and time of visit,
- web page of origin of the visitor (referral) and exit;
- the number of clicks, if any.
2. Such information is processed automatically and exclusively collected in an aggregated form in order to verify the proper functioning of the site, and for security reasons. This information will be processed according to the legitimate interests of the controller.
3. For security purposes (spam filters, firewalls, virus detection), automatically recorded data may also include personal data, such as the IP address, which could be used in accordance with applicable laws, in order to block attempts to damage the site itself or to cause damage to other users, harmful activities or activities constituting a crime. Such data are never used for the identification or profiling of the user, but only for the protection of the site and its users.
4. In case the website allows to comment, or regarding specific services requested by the user, the website automatically detects and records certain identification data of the user, including the email address. These data are voluntarily provided by the user at the time of the request to provide the service. By commenting or providing other information the user expressly accepts the privacy policy and in particular consents to the communication of the content to third parties. The data received will be used exclusively for the provision of the requested service and only for the time necessary to provide the service.
5. The information that the users of the website want to make public through the services and tools made available by the website itself, must be provided by the user knowingly and voluntarily, exempting this site from any liability for any violations of the law. It is up to the users to verify that they can enter personal data of third parties or content protected by national and international standards.
Purposes of data processing
1. The data collected by the website during the navigation are processed by the controller, the processors and the other authorized persons for the following purposes:
• allow site navigation;
• carry out analysis of visitors’ traffic;
• create the account to access to the reserved area and to perform operations related to the same reserved area;
• download purchased digital content;
• issue invoices; • send newsletters and/or advertising content.
2. The data collected by the website are used exclusively for the purposes indicated above and stored for the time strictly necessary to carry out the activities specified.
3. The data used for security purposes (blocking attempts to damage the site) are stored for as long as it is strictly necessary.
Data provided by the user
1. As indicated above, the optional, explicit and voluntary sending of emails to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, necessary to answer to the requests, and any other personal data included in the message.
V- RIGHTS OF THE USER
1. The https://writeapp.io website informs the user of his or her rights. In particular, the data subject has the right to request access to the controller: the access to personal data (art. 15 EU Regulation 2016/679), the rectification (art. 16 EU Regulation 2016/679), the erasure, cd. “right to be forgotten” (art. 17 EU Regulation 2016/679), the data portability (art. 20 EU Regulation 2016/679), the restriction of processing (art. 18 EU Regulation 2016/679) or the objection, for legitimate reasons, to processing (art. 21 EU Regulation 2016/679).
2. The requests may be addressed to the DPO without formality or, alternatively, using the form provided by the Data Protection Supervisor, by sending an email to: dpo@streetlib.com
3. In case the processing is based on Art. 6 (1) (a) of EU Regulation 2016/679 - explicit consent to the processing - or on art. 9 (2) (a) of EU Regulation 2016/679 - explicit consent to the processing of genetic, biometric, health-related data, data concerning religious, philosophical or trade-union beliefs, data revealing racial, ethnic origin or political opinions - the user has the right to revoke the consent at any time without affecting the lawfulness of the processing based on the consent given before the revocation.
4. Likewise, in case of violation of the law, the user has the right to lodge a complaint with the Data Protection Supervisor, as the Authority responsible to supervise the processing in Italy.
5. For a more detailed examination of the rights of the user, see Arts. 15 and ss. of EU Regulation 2016/679.
VI - DATA TRANSFER TO NON-EU COUNTRIES
1. This website may share some of the data collected with services located outside the European Union area. For example with Google, Facebook and Microsoft (LinkedIn) via social plugins and the Google Analytics service. The transfer is authorized and strictly regulated by article 45, par. 1 of EU Regulation 2016/679 and no further consent is required. The companies mentioned above guarantee their adherence to the EU - U.S. Privacy Shield.
2. Data shall never be transferred to third countries which do not comply with the conditions laid down in Article 45 and ss. of EU Regulation 2016/679.
VII - SECURITY OF THE DATA SUPPLIED
1. This website processes user data in a lawful and correct manner, taking appropriate security measures to prevent unauthorised access to, disclosure, modification or deletion of data. The processing is carried out using computer and/ or telematic tools, with organizational methods strictly related to the purposes indicated.
2. In addition to the controller, in some cases, the data may be accessed by categories of persons in charge involved in the organization of the website (for example: administrative, commercial, marketing, legal staff or system administrators) or external parties (as third party technical service providers, mail carriers, hosting providers, IT companies, IT agencies).
VIII- AMENDMENTS TO THIS DOCUMENT
1. This document, published at: https://writeapp.io is the privacy policy of this site.
2. It may be subject to amendments or updates. In case of changes and relevant updates, these will be notified to users.
