PRIVACY POLICY
In this section, in accordance with the European regulation introduced by EU Regulation 679/2016 and Italian legislation (Legislative Decree No. 196/2003), information is provided regarding the processing of personal data of Users who browse the pages of the website www.licensel.com (hereinafter: "Site") or who make use of the purchase services made available thereon (hereinafter "Users" or "Data Subjects").
This notice is provided exclusively for the Site and not for any other websites that the user may visit through links present within the Site.
Data Controller
The Data Controller for the personal data of users of the website www.licensel.com is Digicode Solution LLP (hereinafter also "Company"), Partnership No. OC454045, with registered office in London, 5th Floor, 22 Eastcheap, EC3M 1EU. Email address: info@licensel.com.
Email to contact the controller and request the deletion of your data, where collected, with your prior consent: info@licensel.com.
A - Types of Data Processed
I. Identifying Data
In accordance with the European regulation introduced by EU Regulation 679/2016, browsing the Site and any purchase of products sold on the Site may involve the processing of data capable of directly or indirectly identifying a natural person, such as: first name, last name, residential address, e-mail address, telephone number, IP address.
The Site does not require the Data Subject to provide so-called "special" data, i.e., as provided for by the GDPR (Art. 9), personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to health or sex life or sexual orientation. Should the requested service require the processing of such data, the Data Subject will receive a prior specific notice and will be asked to provide explicit consent.
II. Banking Data
Upon purchasing products available on the Site, banking data will also be processed, such as the card or bank account number provided for payment, the cardholder and bank account holder.
Such data may only be processed by third-party companies managing the payment methods used on the site.
Please note that the Site uses the following payment services, whose respective privacy policies govern the processing of data:
III. Navigation Data
Navigation data is automatically acquired by the systems and programmes responsible for the operation of the Site and is necessary for the use of web services [e.g. IP addresses, browser used, domain names of the systems used by users to connect to the web portal, URI (Uniform Resource Identifier) addresses of the requested resources, 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 (success, error, etc.) and other parameters relating to the user's operating system and computing environment].
Such data is acquired even in the absence of registration to the Site or a request for information.
Navigation data is used exclusively in aggregate form to produce anonymous statistics on Site usage and to monitor its correct functioning, and does not allow the identification of the users concerned; it is also deleted immediately after anonymous processing.
It may, however, be used to establish liability in the event of computer crimes committed against the website.
IV. Data Voluntarily Provided by the User
Personal data voluntarily provided by the User (such as first name, last name, telephone number, e-mail address) for the purpose of sending messages to the Site and/or purchasing the products made available is used solely for the purpose of responding to the data subject's needs and to comply with legal obligations.
The legal basis for such processing is the fulfilment of the obligations relating to the requests made and purchases completed, as well as compliance with legal obligations.
Information that the Site User chooses to make public through the services and tools made available on the Site is provided by the User knowingly and voluntarily, exempting the Site from any liability regarding possible violations of law.
It is the User's responsibility to verify that they have permission to enter personal data of third parties or content protected by national and international regulations.
V. Data Collected via Analytical Cookies
The Site also collects data relating to the User through the use of cookies.
For further information on data processed via cookies, the types of cookies in use and how to disable them, please refer to the cookie policy.
These cookies are used to track the user's browsing preferences and to collect statistical data. The user may disable these cookies by accessing their browser settings, as indicated in the Site's cookie policy.
B - Purposes of Processing
The personal data collected is used to:
- enable the delivery by e-mail of products purchased by the User;
- respond to contact requests sent by the User;
- allow the User to use the Customer Service;
- obtain anonymous statistical information on the use of the web portal;
- monitor the correct functioning of the web portal;
- send communications and newsletters, both in printed and electronic format, to the e-mail address provided by the User: should the user decide to subscribe to the www.licensel.com newsletter only following specific consent, personal data will be processed by the Data Controller for the purpose of sending commercial or promotional communications, updates relating to, for example, exclusive offers, special events and promotions. To unsubscribe from the newsletter, simply click on the unsubscribe link at the bottom of the emails received or write to info@licensel.com;
- establish liability in the event of hypothetical computer crimes against the website;
- comply with any other legal obligation not included in the preceding purposes.
Data may only be communicated following a request by the Judicial Authority within the terms of the law.
C - Legal Basis for Processing
The legal basis for the processing of personal data is the fulfilment of the obligations inherent to the relationship established upon acceptance of the Terms and Conditions, the data subject's consent, compliance with legal obligations, and the legitimate interest of the Data Controller in carrying out processing necessary for such purposes.
I. Performance of a Contract
The Controller processes Personal Data relating to the User when processing is necessary for the performance of a contract with the User and/or for the execution of pre-contractual measures.
II. Consent of the Data Subject
The optional, explicit and voluntary sending of e-mails, messages or any type of communication addressed to the contact details indicated on this Site entails the subsequent acquisition of the sender's address, telephone number or any other personal data that will be used to respond to the requests. Such processing is based on the consent of the data subject.
It is assured that such processing will be governed by the principles of lawfulness, fairness, transparency, adequacy, relevance and necessity as set out in Art. 5, paragraph 1 of the GDPR. Specific summary notices will progressively be included or displayed on the pages of the sites set up for particular services upon request.
III. Compliance with Legal Obligations
The processing of personal data may take place without the data subject's consent in cases where the Controller must comply with a legal obligation.
IV. Legitimate Interest of the Data Controller
The Controller processes Personal Data relating to the User where processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.
V. Optional Nature of Data Provision
Apart from what is specified for the fulfilment of a contract or legal obligations, for cookies and navigation data, the user is free to provide or not provide their personal data. However, failure to provide data may result in the inability to obtain what the execution of the service requires.
D - Methods and Duration of Processing
Personal data is processed through IT tools and in accordance with EU Regulation No. 679/2016.
The retention of processed data will last for the time necessary for the purposes described in this notice and, therefore, for the minimum time required or until an explicit request by the data subject, and in any case within the time limits imposed by law.
The Controller undertakes to adopt all appropriate security measures to prevent the loss and alteration of personal data, as well as any unlawful and unauthorised use thereof.
Data will be processed exclusively by subjects authorised by the Controller, including any data processors, representatives and public bodies for compliance with legally required obligations, who carry out their respective processing activities as independent controllers.
Subjects authorised by the Controller who may process data include, by way of example: staff from the commercial and legal departments, as well as third-party technical service providers, hosting providers and IT companies (this list is not to be considered exhaustive). Processed data will not, however, be disseminated to unidentified recipients.
Subjects authorised by the Controller who may process data for profiling purposes include the online marketing platforms Klaviyo, Omnisend and WordPress.
The security of the information collected cannot be guaranteed against possible hacker attacks and, in general, against breaches of the security measures put in place to protect data.
In the event of attacks or breaches, these will be communicated to data subjects and competent authorities in accordance with applicable law.
E - Place of Processing
Processing related to web portal services is carried out by identified staff expressly designated according to the specific purposes of the requested and subscribed services.
For the processing in question, the Controller may make use of external companies, couriers, consultants, consortia, software and service providers operating through identified and appointed staff, within the scope of the envisaged purposes and in a manner that guarantees maximum security and confidentiality of data. In other cases, the personal data collected will not be disclosed to third parties, unless the data subject's explicit consent has been given, except where communication to third parties is necessary to comply with obligations imposed by laws, regulations or orders of supervisory authorities, or is essential to protect the rights of other users or of the website itself.
Personal data will be processed and stored, solely for the purposes indicated above and to keep it secure and archived, on remote servers managed by leading industry providers that ensure compliance with high standards of protection in terms of personal data processing.
This may involve the transfer of data to non-EU countries where all or part of the aforementioned servers may be located.
In particular, personal data may be transferred outside the European Union to the company WordPress, an e-commerce plugin used by the Site managed by the Controller.
The processing and storage of data by said provider will take place in a "adequate" third country within the meaning of the decision taken by the European Commission, in particular the adequacy decision regarding the protection provided by the Canadian Personal Information Protection and Electronic Documents Act or Privacy Shield certification (USA), or on the basis of a contractual obligation or standard contractual clauses approved by the European Commission, or binding corporate rules approved through the specific procedure referred to in Art. 47 GDPR.
For the transfer of data to non-EU countries, national authorisation from the Data Protection Authority is generally not required. However, the Authority's authorisation will still be necessary if a controller wishes to use specific contractual clauses not recognised as adequate by a decision of the European Commission, or administrative agreements concluded between public authorities.
F - Rights of Data Subjects
During the processing period, the data subject may exercise the following rights at any time:
- obtain confirmation of the existence or otherwise of the same data and, if so, to know its content and origin;
- verify its accuracy and request the rectification of inaccurate data, the integration of incomplete data or the updating of outdated data;
- obtain the restriction of processing, where one of the cases provided for in Article 18 GDPR applies;
- request the deletion of data processed in violation of the law, or in the presence of one of the other conditions provided for in Article 17, paragraph 1, letters a), b), c), e) and f) GDPR;
- object in any case, for legitimate reasons, to their processing, or to object to processing in the other cases provided for in Article 21, paragraphs 2 and 3 and 22 GDPR;
- withdraw at any time their freely given consent to the processing of personal data for the specified purposes;
- obtain the release of the personal data subject to processing in a format compatible with standard IT applications, to allow its transfer to other platforms of their choice, without placing obstacles to the direct transmission of processed data to another Data Controller, where such direct transmission is technically feasible (so-called right to data portability).
Requests relating to the exercise of the above rights should be addressed to the Controller via e-mail (info@licensel.com).
In the event of no or partial response from the Controller to the above requests, the data subject shall have the right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it) or to seek judicial redress within the terms and in the manner provided for under Articles 77 et seq. of EU Regulation 2016/679 (GDPR).
G - Updates to this Notice
Future regulatory updates may lead to amendments to the current notice, uploaded to the Site on 20.01.2023.
In the event of any amendment, the Controller will notify users on the Site.
