1. INTRODUCTION – WHO WE ARE?
   Redify S.r.l. , having its registered office in Piazza Minghetti 4/D - 40124 Bologna (BO) - Italia, VAT No. and Fiscal Code No. IT03973831203 (hereinafter, “Data Controller”), manager of the present internet website (hereinafter, the “Website”), in its capacity as data controller in relation to personal data pertaining to the users using the Website (hereinafter, the “Users”) hereby provides the privacy policy pursuant to art. 13 of the Regulation EU 2016/679 of the Council of 27 April 2016 (hereinafter, “Regulation” or “Applicable Law”).
   

2. HOW TO CONTACT US?
   The Data Controller takes the utmost account of Users’ right to privacy and protection of personal data. For any information related to this privacy policy, Users may contact the Data Controller at any time, using the following methods:
   

   • registered letter with return receipt to the following address Piazza Minghetti 4/D - 40124 Bologna (BO) - Italia

   • by e-mail (to the following address: privacy@redify.co)

   
   The Company did not appoint a Data Protection Officer (DPO), because the Controller is not subject to the mandatory obligation to appoint it pursuant to art. 37 of the Regulation.
   

3. WHAT DO WE DO? - PROCESSING PURPOSES
   By browsing the Website, the User may contact the Data Controller for various purposes such as, purely by way of example, requesting more information on the services offered by the Data Controller on the Website; scheduling a demo. The User may also subscribe to the newsletter, from the Website's dedicated section, in order to be updated on the Data Controller's services.
   
   In relation to these activities, the Data Controller collects personal data relating to the Users.
   
   Particularly, the personal data of the Users will be lawfully processed for the following purposes:
   

   • a) processing the User’s request: The user data collected by the Data Controller for the purpose of any contact request on the Website include: first name, last name, as well as any personal information of the User that may have been voluntarily published in the free field. The User's personal data will be used by the Data Controller for the sole purpose of ascertaining the identity of the User, thus avoiding possible fraud or abuse, and contacting the User for service purposes only (e.g. responding to his/her request for information). No other processing will be carried out by the Data Controller in relation to the Users’ personal data. Without prejudice to what is provided elsewhere in this privacy policy, in no case will the Data Controller make the personal data of the Users accessible to other Users and/or third parties;

   • b) legal obligations , i.e., to comply with obligations imposed by law, an authority, a regulation, or European legislation.

   
   The provision of personal data for the above-mentioned processing purposes is optional but necessary, since failure to provide such data will make it impossible for the User to make their request to the Data Controller.
   
   

4. OTHER PROCESSING PURPOSES
   4.1 Newsletter
   Some of the User’s personal data (i.e. e-mail address) may also be processed by the Data Controller for the purpose of sending a newsletter. Therefore, the User will receive a periodic newsletter from the Data Controller containing information, updates and news in relation to Website activities and/or the services offered by the Data Controller.
   
   In case of lack of consent, the possibility for the User of browsing the Website and/or contacting the Data Controller for the purposes set out in paragraph 3, will not be affected in any way.
   
   In case of consent, the User may at any time revoke the same, making a request to the Data Controller in the manner indicated in paragraph 8 below.
   
   The User can also easily oppose further sending of promotional communications via e-mail by clicking on the appropriate link for the revocation of consent, which is present in each promotional email. Once the consent has been revoked, the Data Controller will send the User an e-mail message confirming the revocation of the consent.
   
   

5. LEGAL BASIS FOR PROCESSING
   Processing the User’s request (as described in the previous paragraph 3, letter a)): the legal basis consists of art. 6, paragraph 1, lett. b) of the Regulation, or the processing is necessary for the performance of a contract to which the User is party or in order to take steps at the request of the data subject prior to entering into a contract.
   
   Legal obligations (as described in the previous paragraph 3, letter c)): the legal basis consists of art. 6, paragraph 1, lett. c) of the Regulation, as the processing is necessary for compliance with a legal obligation to which the Data Controller is subject.
   
   Other processing purposes (as described in paragraph 4.1 above) for the processing relating to the sending of the newsletter, the legal basis is Article 6, paragraph 1, letter a) of the Regulation, i.e., the provision by the data subject of consent to the processing of his/her personal data for one or more specific purposes. For this reason, the Data Controller asks the User to provide a specific free and optional consent, in order to pursue such processing purpose.
   
   

6. PROCESSING METHODS AND DATA RETENTION PERIOD
   The Data Controller will process the personal data of Users using manual and IT tools, with logic strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of the data.
   
   The personal data of Users will be retained for the time strictly necessary to carry out the main purposes explained in paragraph 3 above or, in any case, as necessary for the protection in civil law of the interests of both the Users and the Data Controller.
   
   In the case referred to in paragraph 4.1 above, Users' personal data shall be stored for the time strictly necessary to fulfil the purposes set out therein and, in any case, until Users revoke their consent.
   
   

7. TRANSMISSION AND DISSEMINATION OF DATA
   The personal data of the Users may be disclosed to the employees and/or collaborators of the Data Controller in charge of managing the Website and the Users’ requests. These subjects, who have been instructed to do so by the Data Controller pursuant to Article 29 of the Regulation, will process the User’s data exclusively for the purposes indicated in this policy and in compliance with the provisions of the Applicable Law.
   
   The personal data of the Users may also be disclosed to third parties who may process personal data on behalf of the Data Controller as “Data Processors” pursuant to Article 28 of the Regulation, such as, for example, IT and logistic service providers functional to the operation of the Data Controller’s Website, suppliers of outsourcing or cloud computing services, professionals and consultants.
   
   Users have the right to obtain a list of any data processors appointed by the Data Controller, making a request to the Data Controller in the manner indicated in paragraph 8 below.
   
   

8. RIGHTS OF THE DATA SUBJECTS
   Users may exercise their rights granted by the Applicable Law by contacting the Data Controller as follows:
   registered letter with return receipt to the following address Piazza Minghetti 4/D - 40124 Bologna (BO) - Italia
   by e-mail to the following address: privacy@redify.co
   
   The Company did not appoint a Data Protection Officer (DPO), because the Controller is not subject to the mandatory obligation to appoint it pursuant to art. 37 of the Regulation.
   
   Pursuant to the Applicable Law, Users have:

   • a) the right to withdraw consent at any time, if the processing is based on their consent;

   • b) the right of access to personal data;

   • c) (where applicable) the right to data portability (the right to receive all personal data concerning them in a structured, commonly used and machine-readable format), the right to restriction of processing of personal data, the right to rectification and the right to erasure ("right to be forgotten");

   • d) the right to object:

     • i) in whole or in part, for legitimate reasons to the processing of personal data concerning them, even if relevant to the purpose of collection;

     • ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;

   • e) if they consider that the processing of their personal data is in breach of the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State in which they have their habitual residence, in the Member State in which they work or in the Member State in which the alleged breach has occurred). The Italian Supervisory Authority is the Garante per la protezione dei dati personali, located in Piazza Venezia n. 11, 00187 - Rome (https://www.garanteprivacy.it/ ).

The Data Controller is not responsible for updating all links that can be viewed in this cookie policy, therefore whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to such link.