The purpose of this document ("Privacy Policy") is to inform Users about personal data, meaning any information that allows the identification of a natural person ("Personal Data"), collected through the www.lingospell.com website (“Application”).
The Controller, as identified further on, may modify or simply update, in whole or in part, this information by informing Users. Changes and updates will be binding from the time they are published on the Application. The User is therefore invited to read the Privacy Policy every time they access the Application.
In the event of non-acceptance of any changes to this Privacy Policy, Users are required to cease using this Application and may request that the Controller deletes their Personal Data.
1. Personal Data collected through the Application
The Controller collects the following types of Personal Data:
A. Content and information provided voluntarily by the User
■ Contact details and content: means Personal Data that the User voluntarily provides through the Application during its use, such as personal details, contact details, product/service access credentials, personal interests and preferences and other personal content, etc.
Failure by the User to provide Personal Data, for which there is a legal, contractual obligation, or whenever such data is a requirement for the use of the service or for the conclusion of the contract, the Controller will be unable to provide its services, in whole or in part.
The User who discloses Personal Data to a third-party Controller is directly and solely responsible for the origin, collection, processing, disclosure or dissemination of such data.
B. Data and content collected automatically during use of the Application:
■ Technical data: computer systems and software procedures used to operate this Application may be collected during their normal operation and some Personal Data whose transmission is implicit in the use of internet communication protocols. This information is not collected with the intent of associating it with identified Users but, by its very nature, could lead to the identification of Users through processing and through association with Personal Data held by third parties. This category of data includes IP addresses or domain names used by Users connecting to the Application, URI addresses (Uniform Resource Identifier) of the resources requested, the time of the request, the method used to submit the request to the server and the file size obtained, etc.
■ Usage data: Personal Data regarding the use of the Application by the User may also be collected, such as pages visited, actions performed, and the features and services used.
■ Geolocation data: the Application may collect Personal Data on the User's location which may be GNSS (Global Navigation Satellite System, for example, GPS data) in addition to data that identify the nearest repeater, Wi-Fi hotspots and Bluetooth, communicated when you enable location-based products or features.
C. Personal data collected through cookies or similar technologies:
The Application uses cookies, web beacons, unique identifiers and other similar technologies to collect Personal Data in the pages and links visited and other actions performed when using our services. They are stored before being transmitted back to the same sites on the next visit by the same User.
The User may view the full Cookie Policy at the following address: https://lingospell.com/cookies-policy.
Personal Data collected may be used for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract and for legal compliance, as well as for the following purposes:
o Sending e-mails or newsletters and mailing list management: for contacting the User with e-mails containing commercial and promotional information relating to the Application.
Personal Data are disclosed to us for:
o Monitoring, analysis and tracking of User behaviour: for monitoring and analysing how the User behaves on the Application.
Personal Data are disclosed to analytics.google.com
o Support and contact with the User: for responding to the User's requests and assistance in case of problems.
Personal Data are disclosed to us
o User database management: for organising, accessing and changing User data.
Personal Data are disclosed to us
Personal Data processing is performed using IT and/or electronic telecommunication tools, within organisational procedures and based on principles strictly related and limited to the stated purposes.
In some cases, individuals involved in the Controller's organisation may also have access to Personal Data (such as, for example, personnel management, commercial area employees and system administrators, etc.) or external parties (such as IT companies, service suppliers, mail carriers and hosting providers, etc.). Such parties, whenever necessary, may be appointed as Processors by the Controller, and may access Users' Personal Data whenever required and they will have a contractual duty to keep Personal Data confidential.
The updated list of Managers may be requested via email at: projects@lingospell.com.
Personal data processing regarding the User is based on the following legal rules:
o consent has been given by the User for one or more specific purpose
o processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract
o processing is necessary for compliance with a legal obligation to which the Controller is subject
o processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller
o processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party
or processing is necessary for the purpose of protecting the vital interests of the Controller or a third party.
However, you may contact the Controller and ask for the any lawfulness of processing to be clarified at: projects@lingospell.com.
I Personal Data are processed at the Controller's operational headquarters and in any other place where the parties involved in processing are located. For more information, please contact the Controller at the following e-mail address: projects@lingospell.com or at the following postal address: Via G. Venezian 16, Milan 20133, Italy.
II Processing is performed in a manner and using appropriate tools to guarantee the security and confidentiality of the Personal Data, in that the Controller has adopted adequate technical and organisational measures that ensure, and provide proof, that processing is performed in compliance with relevant legislation.
7. Personal Data retention period
Personal Data will be kept for the period of time necessary to comply with the purposes for which they were collected.
Specifically, Personal Data will be retained for the entire duration of the contractual relationship, for the performance of the relevant and resulting obligations, for compliance with applicable legal and regulatory obligations, as well as for the Controller's own or third-party's legal defence purposes.
Whenever Personal Data processing is based on the User's consent, the Controller may retain the Personal Data until such consent is withdrawn.
Personal Data may be retained for a longer period if required for legal compliance purposes or under an order issued by an authority.
All Personal Data will be deleted or retained in a form that does not allow identification of the User within 30 days after the end of the retention period. Upon expiry of this term, right of access, deletion, rectification and the right to portability of the Data may no longer be exercised.
All Personal Data collected will not be subject to any automated decision-making process, including profiling, which may produce legal effects for the individual or which may affect the data subject significantly.
9. User Rights
Users may exercise certain rights with regard to the Personal Data processed by the Controller. Specifically, as the User, you have the right to:
Withdraw your consent at any time
Object to the processing of your Personal Data
Access your personal data
Check and ask for rectification
Obtain restriction of the processing
Obtain the deletion of your Personal Data
Have your Personal Data sent to you or transferred to another controller
Lodge a complaint with the Data Protection Supervisory Authority and/or take legal action
To exercise rights, Users may send a request to the Data Controller contact details shown in this document. Requests are free of charge and processed by the Data Controller as soon as possible and otherwise within 30 days.
The Controller is LingoSpell s.r.l., with registered office in Via G. Venezian 16, 20133 Milan, Italy, Tax Code/VAT Reg. IT10818950965, e-mail address: projects@lingospell.com, Public Certified E-mail (PEC) address: lingospellsrl@legalmail.it.
Last updated: 30/11/2020