PRIVACY POLICY INTRODUCTION
 
This Privacy Policy explains how White3 S.r.l. (the “Controller”) processes personal data in compliance with the EU General Data Protection Regulation (GDPR). We only collect the minimum amount of personal data necessary to provide and secure our services.


1. Data Controller

• Company name: WHITE 3 S.R.L.

• Registered office: Via Domenico Cimarosa 57, 03043 Cassino (FR), Italy

• Contact email: info@white3.it
  
   

2. Types of data collected
 
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:

• Usage Data

• Trackers

• device information

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or byspecific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make itimpossible for this Application to provide its services. In cases where this Application specifically states that some Data is notmandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of theService.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by thisApplication serves the purpose of providing the Service required by the User, in addition to any other purposes described in thepresent document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

 
4. Mode and place of processing the Data
 
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthoriseddestruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modesstrictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types ofpersons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration)or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies,communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may berequested from the Owner at any time.

Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing arelocated.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. Tofind out more about the place of processing of such transferred Data, Users can check the section containing details about theprocessing of Personal Data.

Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

 
5. The purposes of processing
 
​The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond toenforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulentactivity, as well as the following:

• Traffic optimisation and distribution

• Infrastructure monitoring

• Platform services and hosting

 
6. Detailed information on the processing of Personal Data
 
Infrastructure monitoring
This type of service allows this Application to monitor the use and behaviour of its components so its performance, operation,maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose functionis to filter the activities of this Application.

   Sentry
   Company: Functional Software, Inc.
   Place of processing: United States
   Personal Data processed: various types of Data as specified in the privacy policy of the service


Platform services and hosting
These services have the purpose of hosting and running key components of this Application, therefore allowing the provision ofthis Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, userregistration, commenting, database management, e-commerce, payment processing – that imply the collection and handling ofPersonal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location wherethe Personal Data are stored.

   Wix
   Company: Wix.com, Ltd.
   Place of processing: Israel
   Personal Data processed: device information +2


Traffic optimisation and distribution
This type of service allows this Application to distribute their content using servers located across different countries and tooptimise their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function isto filter communications between this Application and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that maycontain Personal Information of the User are transferred.

   Google Cloud CDN
   Company: Google LLC
   Place of processing: United States
   Personal Data processed: Usage Data
 

7. Further Information for Users in the European Union

Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes.

• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligationsthereof;

• processing is necessary for compliance with a legal obligation to which the Owner is subject;

• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in theOwner;

• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
   

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whetherthe provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall beretained until such contract has been fully performed.

• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfillsuch purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within therelevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing,as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer periodwhenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right torectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

• Withdraw their consent at any time.

• Users have the right to withdraw consent where they have previously given theirconsent to the processing of their Personal Data.

• Object to processing of their Data.

• Users have the right to object to the processing of their Data if the processing iscarried out on a legal basis other than consent.

• Access their Data.

• Users have the right to learn if Data is being processed by the Owner, obtain disclosure regardingcertain aspects of the processing and obtain a copy of the Data undergoing processing.

• Verify and seek rectification.

• Users have the right to verify the accuracy of their Data and ask for it to be updated orcorrected.

• Restrict the processing of their Data.

• Users have the right to restrict the processing of their Data. In this case, the Ownerwill not process their Data for any purpose other than storing it.

• Have their Personal Data deleted or otherwise removed.

• Users have the right to obtain the erasure of their Data from theOwner.

• Receive their Data and have it transferred to another controller.

• Users have the right to receive their Data in astructured, commonly used and machine readable format and, if technically feasible, to have it transmitted to anothercontroller without any hindrance.

• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
   

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to anyinternational organisation governed by public international law or set up by two or more countries, such as the UN, and about thesecurity measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with theOwner using the information provided in the contact section.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or forthe purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a groundrelated to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object tothat processing at any time, free of charge and without providing any justification. Where the User objects to processingfor direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether theOwner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of thisdocument.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Suchrequests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Userswith the information required by law. Any rectification or erasure of Personal Data or restriction of processing will becommunicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this provesimpossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

 
8. Additional information about Data collection and processing

Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal actionarising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional andcontextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interactionwith this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please seethe contact information at the beginning of this document.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possiblywithin this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact informationavailable to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed atthe bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consentfrom the User, where required.

 

9. Definitions and legal references

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number —allows for the identification or identifiability of a natural person.

Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which caninclude: the IP addresses or domain names of the computers utilised by the Users who use this Application, the URI addresses(Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the filereceived in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the countryof origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the timespent on each page within the Application) and the details about the path followed within the Application with special referenceto the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, asdescribed in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposesand means of the processing of Personal Data, including the security measures concerning the operation and use of thisApplication. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states tothe European Union and the European Economic Area.

Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting -that enables the tracking of Users, for example by accessing or storing information on the User’s device.


10. How can we help?

For any questions about this Privacy Policy or to exercise your rights, please contact us at: info@white3.it