ZOTUP S.r.l. collects some Personal Data from its Users.
ZOTUP S.r.l. (referred to as “Data Controller”, “the company”, “we”, “us”, “our” or “ZOTUP” in this statement), with registered office in Via Agostino Depretis, 11 - 24124 Bergamo, Italy.
Ph. +39 035 361035 - Fax +39 035 361025
You can contact us by e-mail at firstname.lastname@example.org
Types of collected Data
Among the Personal Data collected by ZOTUP, independently or through third parties, there are: e-mail, name, surname, addresses, cookies, Usage Data and access information to our website.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of zotup.com. Unless otherwise specified, all the Data requested by ZOTUP are mandatory. If the User refuses to communicate them, it may be impossible for ZOTUP to provide the Service. In case ZOTUP indicates some Data as optional, the Users are free to refrain from communicating such Data, without any consequence on the availability of the Service or its operation.
Users who may have doubts about which data are mandatory, are encouraged to contact us.
The User takes the responsibility on Personal Data of third parties obtained, published or shared by ZOTUP and guarantees to have the right to communicate or disseminate them, freeing the company from any liability to third parties.
How and where we process the collected data
The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of the Users’ Personal Data.
The Processing is carried out using IT and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other parties may have access to the Data, such as subjects involved in the organization of the company's work (administrative, commercial, marketing, legal staff, system administrators) or external subjects (such as suppliers of third party technical services, couriers, hosting providers, IT companies, communication agencies) appointed, if necessary, Data Processors by the Data Controller. The updated list of Data Processors could always be requested to the Data Controller.
Legal basis of the processing
The Data Controller processes the Users’ Personal Data in the event one of the following conditions exists:
- the User has given consent for one or more specific purposes; (Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to this treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation regarding Personal Data protection);
- the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
- the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
- the processing is necessary for the performance of a task carried out in the public interest or for the exercise of public authority with which the Data Controller is vested;
- the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.
In any case, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and, in particular, to specify whether the treatment is based on the law, provided by a contract or necessary to conclude a contract.
Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For more information, please contact us.
The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the processing site, the User can refer to the section concerning the processing of Personal Data.
The User has the right to obtain information regarding the legal basis for Data transfer outside the European Union or transfer to an international organization of public international law or an organization consisting of two or more countries, such as the UN, as well as information regarding the security measures taken by the Data Controller to protect the Data.
If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information to the Data Controller by contacting us.
The Data are processed and stored for the time required by the purposes for which they were collected.
Personal Data collected for purposes related to the execution of a contract between the company and the User will be retained until the execution of the contract is completed.
Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is met. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting us.
When the processing is based on the consent of the User, the Data Controller may retain the Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period, in compliance with a legal obligation or an order of an authority.
At the end of the retention period, Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to Data portability can no longer be exercised.
Purposes of Data processing
The User’s Data are collected to allow ZOTUP to provide its Services, as well as for the following purposes: to contact the User, interaction with social networks and external platforms, statistics and display of content from external platforms.
To obtain further detailed information on the purposes of the processing, the User can refer to the relevant sections of this document.
Details on Personal Data processing
Personal Data are collected for the following purposes and using the following services:
> Contact the User
> Mailing list or newsletter (via MailUp platform or direct mailing or other software for mailing)
By registering to the mailing list or the newsletter, the User's email address is automatically added to a list of contacts to which can be transmitted email messages containing information, including commercial and promotional information, related to ZOTUP. The User's email address could also be added to this list as a result of registration to the website zotup.com or after making a purchase.
The possibility of indicating that you no longer wish to receive direct marketing material is also given in every electronic communication that will be sent by ZOTUP.
Collected Personal Data: name, surname, email address, telephone number, physical address, professional category, company and role in the company.
> Interaction with social networks and external platforms
This type of service allows interaction with social networks, or with other external platforms, directly from ZOTUP pages.
The interactions and information acquired by ZOTUP are in any case subject to the User's privacy settings related to any social network (such as Facebook, LinkedIn, YouTube, Google+).
If an interaction service with social networks is installed, it is possible that, even if Users do not use the service, the same service collects traffic data relating to the pages in which it is installed.
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of Users’ behavior.
> Google Analytics (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google uses Personal Data collected for the purpose of tracking and analyzing the use of zotup.com, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize the advs of its advertising network.
Personal Data collected: Cookies and Usage Data.
> Content displaying from external platforms
This type of service allows you to view content hosted on external platforms directly from ZOTUP pages and interact with them.
In the event that a service of this type is installed, it is possible that, even if Users do not use the service, the same service collects traffic data related to the pages in which it is installed.
> Google Fonts (Google Inc.)
Google Fonts is a service of visualization of font styles managed by Google Inc. that allows ZOTUP to integrate such contents within its pages.
> Widget Google Maps (Google Inc.)
Google Maps is a map visualization service managed by Google Inc. that allows ZOTUP to integrate such contents within its pages.
Personal Data collected: Cookies and Usage Data.
Users may exercise certain rights with reference to the Data processed by the Data Controller.
In particular, the User has the right to:
> withdraw consent at any time. The User can withdraw the previously expressed consent to the processing of his/her Personal Data.
> oppose the processing of his/her Data. The User may object to the Data processing when it occurs on a legal basis other than consent. Further details on the right of opposition are indicated in the section below.
> access his/her Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the processed Data.
> verify and request rectification. The User can verify the correctness of the Data and request its updating or correction.
> obtain the limitation of the Data processing. When certain conditions are met, the User may request the limitation of the processing of his/her Data. In this case, the Data Controller will not process the Data for any other purpose other than their conservation.
> obtain the cancellation or removal of his/her Personal Data. When certain conditions are met, the User can request the Data cancellation by the Data Controller.
> receive his/her Data or have them transferred to another holder. The User has the right to receive his/her data in a structured and readable by automatic device format and, where technically feasible, to obtain the transfer to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it.
> to propose a complaint. The User can lodge a complaint with the competent personal data protection authority or act in court.
Details on the right of opposition
When Personal Data are processed in the public interest, in the exercise of public authority to which the Data Controller is invested or to pursue a legitimate interest of the company, Users have the right to oppose the processing for reasons related to their particular situation.
Users are reminded that, if their Data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the company deals with Data for direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise the rights
To exercise their rights, Users can direct a request to the company, using the contact details indicated in this document. The requests are deposited free of charge and processed by the Owner as soon as possible, in any case within a month.
More information on processing
Defense in court
The User's Personal Data may be used by the Data Controller in court or in the preparatory stages of its possible establishment for defend from potential abuses in the use of ZOTUP or of related Services by the User.
The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of the public authorities.
System logs and maintenance
For needs related to operation and maintenance, ZOTUP and any third-party services used may collect system logs, which are files that record the interactions and that may also contain Personal Data, such as the IP address of the User.
Information not contained in this Policy
Further information in relation to the processing of Personal Data may be requested to the Data Controller at any time using the contact details.
Response to "Do Not Track" requests
ZOTUP does not support "Do Not Track" requests.
To find out if any used third-party services support them, the User is invited to consult their respective privacy policies.
If the modifications concern treatments whose legal basis is consent, the Controller will collect the User's consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
Personal Data consist in any information that, directly or indirectly, also in connection with any other information, makes a physical person identified or identifiable (including personal identification number).
It is information automatically collected through zotup.com (also from third party applications integrated into zotup.com), including: IP addresses or domain names of the computers used by the User that connects with zotup.com, addresses in URI (Uniform Resource Identifier), the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (success, error, etc.), the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, to the parameters related to the operating system and the IT environment of the User.
The person who uses the website and communication tools (emails, newsletters, calls) of ZOTUP that, unless otherwise specified, coincides with the interested party.
The interested party
The natural person to whom the Personal Data refers.
Data Manager (or Manager)
Data Controller (or Holder)
The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures related to the operation and fruition of zotup.com. The Data Controller, unless otherwise specified, is the owner of zotup.com.
The hardware or software tool through which the Users’ Personal Data of usage are collected and processed.
The Service provided by ZOTUP as defined in the relevant terms on this site/application.
European Union (o EU)
Unless otherwise specified, any reference to the European Union contained in this document shall be extended to all current member states of the European Union and to the European Economic Area.
Small portion of data stored in the User's device.
This privacy statement is drawn up on the basis of multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy statement only concerns ZOTUP.
Last modification: 25 May 2018