Pursuant to the Applicable Law, the data controller is Sunrise Technology di Christian Marcante, with registered office at Via G. Casaregis 45/10 – 16129 Genoa (Italy) (hereinafter only “SUNRISE”), as data controller of personal data pursuant to Legislative Decree 196/2003 as amended – Personal Data Protection Code (“Privacy Code”) – and EU Regulation 679/2016, applicable from 25 May 2018 – General Data Protection Regulation (“GDPR”) (hereinafter the Privacy Code and the GDPR are collectively referred to as the “Applicable Law”), recognizes the importance of personal data protection and considers its protection one of the main objectives of its activity. Before providing any personal data, SUNRISE invites you to read this privacy policy (“Privacy Policy”) carefully, as it contains important information on the protection of personal data and on the security measures adopted to guarantee its confidentiality in full compliance with the Applicable Law. This Privacy Policy, moreover: is issued only for the site https://www.sunrisetechnology.it/ (“Site”) and does not apply to other websites that may be visited through external links; is to be understood as the information notice provided pursuant to Article 13 of the Applicable Law to those who interact with the Site; complies with Recommendation No. 2/2001 on the minimum requirements for the collection of personal data on-line in the European Union, adopted on 17 May 2001 by the Article 29 Working Party.
SUNRISE informs you that the processing of your personal data will be based on the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality. Your personal data will therefore be processed in accordance with the legislative provisions of the Applicable Law and the confidentiality obligations provided for therein.
TABLE OF CONTENTS
Below is the table of contents of this Privacy Policy so that you can easily find the information concerning the processing of your personal data.
1. DATA CONTROLLER AND DATA PROTECTION OFFICER
2. PERSONAL DATA PROCESSED
a. Browsing data
b. Data provided voluntarily
c. Cookies and similar technologies
3. PURPOSES, LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING
4. RECIPIENTS
5. TRANSFERS
6. DATA RETENTION
7. YOUR RIGHTS
8. CHANGES
9. CUSTOMER INFORMATION NOTICE DOWNLOAD
10. ARTIFICIAL INTELLIGENCE (AI)
1. DATA CONTROLLER AND DATA PROTECTION OFFICER (DPO)
SUNRISE, as Data Controller pursuant to EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data, following a specific assessment has been found not to be required to appoint a Data Protection Officer in compliance with Art. 37 of EU Regulation 2016/679 and the “Guidelines on Data Protection Officers” amended and adopted on 5 April 2017. For any information concerning the processing of SUNRISE's personal data, including the list of the processors handling data, you can contact the controller at the address info@sunrisetechnology.it, or by phone at +39 3493705567.
2. PERSONAL DATA PROCESSED
“Personal Data” means any information relating to an identified or identifiable natural person, with particular reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more elements characteristic of their physical, physiological, mental, economic, cultural or social identity.
The Personal Data collected by the Site are as follows:
a. Browsing data
The Site's computer systems collect some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected in order to be associated with you, but which by its very nature could, through processing and association with data held by third parties, allow you to be identified. This includes the IP addresses or domain names of the devices you use to connect to the Site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to your operating system and computing environment. These data are used to obtain anonymous statistical information on the use of the Site and to check that it is working correctly; to allow – given the architecture of the systems used – the correct delivery of the various functions you request, for security reasons and to establish liability in the event of hypothetical computer crimes against the Site or third parties, and are deleted after 7 days.
b. Data provided voluntarily
Through the Site you may voluntarily provide Personal Data such as your name and email address, in order to contact SUNRISE through the “Contact us” link or to subscribe to the newsletter service and receive commercial, informational or promotional communications about the services and content of Sunrise Technology, subject to the user's specific consent. SUNRISE will process this data in compliance with the Applicable Law, assuming that it refers to you or to third parties who have expressly authorized you to provide it on the basis of a suitable legal basis that legitimizes the processing of the data in question. In such cases, you act as an independent data controller, assuming all obligations and legal liabilities. In this regard, you grant the broadest indemnity against any claim, demand or request for damages for processing that may be made against SUNRISE by third parties whose Personal Data have been processed through your use of the Site in breach of the Applicable Law.
c. Cookies and similar technologies
SUNRISE collects Personal Data through cookies. More information on the use of cookies and similar technologies is available here.
3. PURPOSES, LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING
The Personal Data you provide through the Site will be processed by SUNRISE for the following purposes:
a) purposes relating to the performance of a contract to which you are a party or to the performance of pre-contractual measures taken at your request (e.g. contact request through the Contact form, etc.);
b) purposes of statistical research/analysis on aggregated or anonymous data, therefore without the possibility of identifying the user, aimed at measuring the functioning of the Site, measuring traffic and assessing usability and interest;
c) purposes relating to the fulfilment of a legal obligation to which SUNRISE is subject;
d) purposes necessary to establish, exercise or defend a right in court or whenever the judicial authorities exercise their judicial functions;
e) purposes of sending informational and promotional newsletters, guides, tutorials, news, curiosities and tips relating to the services and content of Sunrise Technology, subject to the user's specific consent.
The legal basis for the processing of Personal Data for the purposes referred to in point a) is the provision of a service or a reply to a request that do not require consent under the Applicable Law.
The purpose referred to in point b) does not involve the processing of Personal Data, the purpose in point c) concerns the fulfilment of a legal obligation, while the purpose referred to in point d) represents a lawful processing of Personal Data under the Applicable Law since, once the Personal Data have been provided, the processing is indeed necessary to fulfil a legal obligation to which SUNRISE is subject. The legal basis for the processing for the purpose referred to in point e) is instead the free, specific, informed and unambiguous consent of the user, pursuant to Art. 6(1)(a) of the GDPR; such consent may be withdrawn at any time, without affecting the lawfulness of the processing based on the consent given before its withdrawal, by contacting SUNRISE at the addresses indicated in point 1 or through the appropriate unsubscribe link in every communication. The provision of your Personal Data for the purposes referred to in points a), b), c) and d) is optional, but any failure to provide them could make it impossible to respond to your request or to fulfil a legal obligation to which SUNRISE is subject; the provision of Personal Data for the purpose referred to in point e) is likewise optional and the lack of consent only results in the impossibility of receiving the newsletter, with no consequences for the use of the Site or other services requested.
Processing and Retention of data for the Newsletter service
The data collected through the newsletter subscription form (email address) are processed through a double opt-in procedure. The data entered are temporarily stored in the Site's systems for the sole and exclusive purpose of completing the verification and confirmation of the subscription (sending of the confirmation link and verification of the user's click); once the activation is completed and the relevant notification has been sent to the Controller, such data are removed from the Site's systems.
The permanent storage of the email address for the purpose of sending the newsletter is managed independently by the Controller through its own protected email archives, external to the Site, without any further storage of the data in the database or systems of the Site itself.
Retention period: the data will be kept in the Controller's archives for as long as the newsletter service remains active or until the user decides to withdraw their consent, by requesting to unsubscribe through the link included in every communication or by writing to SUNRISE at the addresses indicated in point 1.
For the technical sending of communications, SUNRISE may use third-party providers of email services (SMTP) and subscription management, appointed as Data Processors pursuant to Article 28 of the GDPR, as indicated in point 4 “RECIPIENTS”.
4. RECIPIENTS
Your Personal Data may be shared, for the purposes specified in point 3, with:
a) parties necessary for the delivery of the services offered by the Site including, by way of example, providers of email sending services (including the newsletter sending service) and providers of the service for analyzing how the Site works, who typically act as data processors of SUNRISE;
b) persons authorized by SUNRISE to process Personal Data who have undertaken to maintain confidentiality or are under an appropriate statutory obligation of confidentiality; (e.g. employees and collaborators of SUNRISE); (a. and b. are collectively “Recipients”);
c) judicial authorities in the exercise of their functions when required by the Applicable Law.
5. TRANSFERS
Your Personal Data are not transferred to Recipients located outside the European Economic Area. SUNRISE ensures that if this were to happen in the future, it would always be in compliance with the Applicable Law. Indeed, transfers would be based alternatively on an adequacy decision or on the Standard Model Clauses approved by the European Commission. More information and a copy of these agreements would be available from SUNRISE.
6. DATA RETENTION
SUNRISE will process your Personal Data for the time strictly necessary to achieve the purposes indicated in point 3. By way of example, for the Newsletter service please refer to what is specifically stated in the paragraph “Processing and Retention of data for the Newsletter service” in point 3. Without prejudice to the above, SUNRISE will process your Personal Data for the time permitted by Italian law to protect its own interests (Art. 2947(1)(3) of the Italian Civil Code). More information on the retention period of Personal Data and the criteria used to determine this period may be requested by writing to SUNRISE.
7. RIGHTS
Within the limits of the Applicable Law, you have the right to ask SUNRISE, at any time, for access to your Personal Data, their rectification or erasure, or to object to their processing, the restriction of processing, as well as to obtain, in a structured, commonly used and machine-readable format, the data concerning you.
Requests should be sent by email to: info@sunrisetechnology.it
Pursuant to the Applicable Law, you also have the right to lodge a complaint with the competent supervisory authority (the Italian Data Protection Authority – Garante per la Protezione dei Dati Personali) if you believe that the processing of your Personal Data is contrary to the law in force.
8. CHANGES
This Privacy Policy has been in force since May 2018. SUNRISE reserves the right to amend or simply update its content, in part or in full, also as a result of changes in the Applicable Law. SUNRISE will inform you of such changes as soon as they are introduced and they will be binding as soon as they are published on the Site. SUNRISE therefore invites you to visit this section regularly to take note of the most recent and updated version of the Privacy Policy so that you are always up to date on the data collected and the use SUNRISE makes of them.
9. CUSTOMER INFORMATION NOTICE DOWNLOAD
Here you can download the Customer information form pursuant to Art. 13 EU Reg. 2016/679, to be filled in in all its parts and sent by email to the following address: info@sunrisetechnology.it
Customer information GDPR 2016_679.pdf
10. ARTIFICIAL INTELLIGENCE (AI)
Artificial Intelligence (AI): the Site may include content generated or reworked by means of Artificial Intelligence systems. Such tools do not process the personal data of the Site's users.
