operaLogica Srl

PRIVACY AND COOKIE POLICY

Effective Date: 12/15/2020

SUMMARY

Purpose

Scope of Application

How We Obtain Information

How We Use Collected Information

How We Share Collected Information

Legal Basis for Processing

International Data Transfer

Security and Confidentiality

Storage Your Privacy Rights

General

operaLogica Srl,including its subsidiaries and affiliates (collectively, "operaLogica," "we," or "the company") respects the privacy of its customers, business partners, event attendees, job seekers and website visitors (as defined below) .

The following Privacy Policy explains who we are and the different ways we collect, use and share personal information about you and how you can exercise your privacy rights. Please take the time to read this Privacy Policy and related statements in their entirety to ensure that you are fully informed. To access a specific policy, click on the relevant link below. Please note that we may provide additional information about our specific privacy practices for one of our websites, events, products or services.

If you have any questions or concerns about how we use your personal information, please contact us using the contact details provided at the bottom of this Privacy Policy.

PRIVACY POLICY. Our Privacy Policy covers our privacy practices in relation to the collection, use and disclosure of information obtained: (i) through the operaLogica websites which link to this Privacy Policy (our "Website") ; and (ii) events hosted by operaLogica or our business partners and sponsors where we collect information from attendees (“Events”).

INFORMATION ON COOKIES. Our Cookie Policy covers how we use cookies and other similar tracking technologies when you visit our websites or use our products, services and mobile applications.

DECLARATION ON THE PROTECTION OF PRIVACY RELATING TO THE SERVICES. The Services Privacy Statement covers our privacy practices in relation to the use of our hosted software applications and related support services, as well as expert services, including professional services, training courses and the certifications we provide to customers. This Services Privacy Policy also describes our privacy practices with respect to the customer and partner contact information that we process in connection with the purchase and use of our products and services or the services or technologies provided by our partners. to our customers.

Purpose

operaLogica Srl, including its subsidiaries and affiliates (together, "operaLogica," "we," or "the company"), respects the privacy of website visitors (as defined below) and event participants (as defined in following).

This Privacy Policy ("Privacy Policy") describes who we are, the information we collect about you, how we obtain your personal information and how we may use or disclose that information in connection with the Website and Events. This Privacy Policy also describes the measures we take to protect the security of your personal information and how you can contact us about our privacy practices, including the exercise of your privacy rights.

Field of application

Our Privacy Policy covers our privacy practices in relation to the collection, use and disclosure of information obtained: (i) through the operaLogica websites which link to this Privacy Policy (our "Website") ; and (ii) event registrations or information about participation in events hosted by operaLogica or our business partners in which we collect information from subscribers and attendees (“Events”).

How We Obtain Information

As described below, we collect different types of information, from and about you, which fall broadly into the following categories:

1. Information you voluntarily provide to us:

When filling out forms on our website (including but not limited to your name, postal address, email address and telephone number).

When you post material on our website, interact on bulletin boards, chat rooms, blogs, comment threads, forums or other interactive features of our website, you register or request additional information or services from us.

When you register to use a demo or developer instance of our cloud service.

When you enter a contest or promotion we sponsor.

When you report a problem with our website to us.

When you contact us.

When you participate in our surveys.

When you register or attend an Event.

Other information you may submit to us regarding your use of our website or participation in an Event, including but not limited to billing information.

2. Information from third parties.

From time to time, we may collect and use information we receive about you from third parties in connection with your use of the website or participation in an Event. For example, we may receive information about you from our business partners related to Event registration information. In addition, we use information provided by third parties for reporting and data analysis to measure the effectiveness of our website and marketing efforts, as well as to identify areas for improvement.

We may combine information we collect from third parties with information you provide to us to update, expand or provide you with personalized information relating to our products, services and Events.

3. The information we collect as you browse our website.

As you browse our website, we may also automatically collect details about your visits, including your IP address, usage patterns, traffic data, location data, logs and other communication data, and the resources you access. , as well as information about your computer and internet connection, including your operating system and browser type.

We collect some of this information using cookies and similar tracking technologies. For more detailed information, see our Cookie Policy.

How We Use Collected Information

We may use the information we collect about you for the following purposes:

To operate, maintain and improve the site.

To register for the Events you have registered for and fill out your profiles in our archives.

For the purposes of customer relationship management (CRM) if the user registers, the personal data provided by the user by filling in the Company's forms or collected during visits to the Websites or interacting with the Company, namely personal and contact information and data regarding the user's habits and profile will be entered in the centralized CRM system for:

 

to. offer marketing communications on products and services and invitations to events on the Company's brands (organized by the Company), surveys and researches, market analyzes and other initiatives for users or registered customers of the Company's brands ("marketing"). The Company may use traditional means of contact (ordinary mail and telephone) and / or digital and automated (e-mail, SMS, MMS, telephone and other digital channels, for example social media) and may send the user such communications on the the basis of his profile, if he has given his consent to profiling (see point 3.3b below);

b. analyze the user's contacts with the Company, interests, preferences and create individual or aggregate profiles based on them, understand how to provide a better service ("profiling"). The Company may also use personal data to create groups and carry out statistical and market analyzes aimed at identifying services of interest to customers of its brands and improving its services (including the Websites). The processing of personal data for profiling is carried out in compliance with the guarantees and parameters established by the law in force.

The insertion of data in the CRM system is optional and free (being based on the consent that the user can choose to give) and can only take place where the personal data are provided for both the marketing and profiling purposes referred to in points a) and b) (mentioned above) or only for one of the two. The user can unsubscribe or withdraw his consent at any time. In any case, the refusal to provide personal data for one or both of these CRM purposes does not prevent the user from using the Company's services, but the Company will not be able to inform him of the marketing initiatives and events described above and will not be able to understand his interests and offer them a more personalized shopping experience.

To provide you with the information, products or services you request from us.

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including, without limitation, our Website Terms of Use.

To inform you of changes made to our website or to obtain the required consent.

To enable you to take advantage of the interactive features of our website, when you choose to do so.

For industry analysis, benchmarking, metrics, marketing and other business purposes.

To track your browsing behavior, such as the pages you have visited over time, for analytics and advertising purposes.

To communicate with you about the Events.

To contact you for marketing purposes, in accordance with your marketing preferences (for example, we may use your information to contact you in order to further discuss your interest in our services and products or other Events).

After registering with BePeople or other future sites within the operaLogica ecosystem, operaLogica will create a profile that will allow you to access any other listed site using the same username and password. Personal information that may be collected during registration and / or use of any of these sites that you choose to make public may be visible to other users of the sites. Furthermore, your personal data may be used by other sites to improve your experience and the quality of our services.

If you ask us to contact you about goods and services, we may use your personal information, or allow selected third parties to use your personal information, to contact you for that purpose. You can withdraw your consent later by clicking on the “Unsubscribe” link in the emails we send you. For more information, see the “Your Privacy Rights” section below.

Further information about our privacy practices relating to the collection and use of information related to Events can be found in the privacy statements on the registration sites for Events hosted by us.

How We Share Collected Information

We may disclose the personal information you provide to us to the following categories of recipients:

To our subsidiaries and affiliates (including those located outside the European Economic Area and Switzerland) who will use them only for the purposes described in this Privacy Policy.

To our contractors, business partners and service providers that we use to support our Service or who provide services on our behalf. For clarity, operaLogica does not share Event attendee data with business partners or sponsors, unless you consent to such sharing via an Event registration form or participate in an Event hosted by operaLogica and allow our business partners or sponsor to examine your participant badge. If you do not want your information to be shared with our business partners or sponsors, you can choose not to join via the event registration forms and not to have your badge analyzed by a partner during an Event. If you choose to share your information with business partners or sponsors,

To a prospective buyer (and its agents and advisors) in connection with any proposed merger, acquisition or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution or liquidation), in which case the personal information about you held by us will be placed among the assets transferred to the buyer or buyer.

To any competent authority, regulatory authority, government agency, court or other third party to: (i) comply with any court order, request from any competent law enforcement authority or any other legal obligation; (ii) enforce or apply the Terms of Use of our website or the terms of any other agreement; (iii) and protect the rights, property or safety of operaLogica or others.

To any other person with your consent to the disclosure.

We do not sell, rent or exchange information collected through the website with third parties for promotional purposes.

 

The processing of the user's personal data for CRM purposes will be carried out, according to the instructions provided by the Company, by the associated companies that manage the Company's brands locally in Italy and in other countries or online, as data processors.

Legal Basis for Processing

If you reside in a country that is part of the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we generally only collect your personal information if we have your consent to do so, in case we need the aforementioned personal information to enter into a contract with you, or in case the processing is in our legitimate interest and is not overridden. your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect your personal information.

If you have any questions or additional information regarding the legal basis in relation to which we collect and use your personal information, please contact us using the contact details provided in the "Contact Information" section below.

International Data Transfer

operaLogica stores and processes any information collected in connection with the website or an Event in: (i) any country in which we have facilities, (ii) any country in which we have agreements with service providers; or (iii) any country in which the Events take place. A list of operaLogica's international offices is available here.

If you are a visitor from the European Economic Area ("EEA"), we will protect your personal information even when it is transferred outside the EEA:

Processing them in a territory established by the European Commission capable of guaranteeing an adequate level of protection of personal information; or otherwise

Implementing adequate protection capable of safeguarding your personal information, including through the use of standard contractual clauses or another legal transfer mechanism approved by the European Commission.

If you need more information about our international transfers of personal data, please contact us using the contract details in the "Contact Information" section below.

Security and Confidentiality

operaLogica guarantees the adoption of appropriate technical and organizational measures to protect personal information obtained through the website and in relation to Events deriving from accidental or unlawful destruction, loss, alteration, disclosure and unauthorized access. OperaLogica employees and service providers who have access to personal information collected through our websites or from Event participants are required to ensure the security and confidentiality of such information.

storage

We will store your personal information if we have a commercial need that forces us to do so and only for the time necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law (e.g. for example, to comply with applicable laws, taxes or accounting).

If we do not have commercial needs that make it necessary to process your personal information, we will delete or anonymize it or, if this is not possible (for example because your personal information has been stored in the backup archives), we will keep it in a secure and we will isolate you from any further processing until deletion is possible.

Your Privacy Rights

We provide you with some choices regarding the information you communicate to us. In particular:

If you wish to access, correct, update or request the deletion of your personal information, you can send us an email atteam@operalogica.com. Event subscribers and attendees can update their user profiles for the Events we host by logging into the Event website or registration page.

Some jurisdictions, for example the European Economic Area, provide their residents with specific privacy rights under applicable law. We will process your requests to exercise these rights, including in cases where you contest the processing of your personal information, restrict the processing of your personal information or request the portability of your personal information, in accordance with applicable data protection laws. . You can email us at team@operalogica.comor by using the contact details under "Contact Information" below.

If you do not wish to receive our marketing emails for promotional purposes, you can unsubscribe by clicking on the “Unsubscribe” or “Unsubscribe” link in the marketing emails you receive from us. In the event that you no longer wish to receive marketing material (through telemarketing, for example), please contact us using the contact details provided in the "Contact Information" section below.

Furthermore, by processing your personal information based on your consent, you can contact us at any time to exercise your rights and withdraw your consent.

If you are not satisfied with the way we collect and use your personal information, you have the right to lodge a complaint with a data protection authority. For more information, please contact your local data protection authority. Contact details of data protection authorities in the European Economic Area, Switzerland and some non-European countries (including the United States and Canada) can be found here.

We will respond to such requests in accordance with the requirements of applicable data protection laws. To fulfill your request, we may need you to provide certain information to verify your identity.

General

As far as possible, operaLogica undertakes to comply with the Do Not Track instructions

("DNT") sent by your browser. However, we cannot guarantee that operaLogica will recognize and respond to DNT signals as there are no universally accepted industry standards for such technology. We will continue to monitor the evolution of DNT technology to stay updated on the possible introduction of definitive industry standards.

Third Party Websites and Applications

This website may contain links to websites not owned or controlled by operaLogica. Therefore, this Privacy Policy does not apply to information collected on third party sites or third party applications that may be linked to or accessed from the website. This Privacy Policy does not apply to information collected from customers, our partners. commercial and other third parties or third party applications or services, even if this information is collected using our website or Events.

Public Forums and Blogs

All information posted or disclosed in public forums will become public information and may be available to users and the general public without restriction. We encourage you to be very careful when you decide to disclose your personal information or any other information in our public forums. Proper access and use of information provided on the website, including contributions to our public forums, is governed by our Website Terms of Use and known or suspected violations should be reported to our Privacy team by email atteam@operalogica.com

Minors

We do not knowingly collect personal information from anyone under the age of 16. If you are under the age of 16, please do not attempt to fill out our forms or send us personal information about yourself. If we discover that we have collected personal information about a child under the age of 16, we will delete that information immediately.

Changes to Our Privacy Policy

operaLogica reserves the right to update or change this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will notify you using an appropriate online notice or other means (which may include, if we have your contact details, an email notification) and ask for your consent if and where required by law. We ask you to periodically review the Privacy Policy to stay informed of any updates or changes we may have made.

You can check when this Privacy Policy was last updated by checking the “Effective By” date displayed at the top of this Privacy Policy.

Contact info

To ask questions or comments on the Privacy Policy and our privacy practices or if you need to update, change or remove your information, please contact us at:team@operalogica.com.

Or at the following address:

operaLogica SRL.

Via Montenero, 175 / D

20024 Garbagnate Milanese (MI)

Any feedback, comments, suggestions, support requests and other communications relating to the website should be directed to:team@operalogica.com

This website is managed by operaLogica Srl. (The data controller), which is a company based at the address: Via Montenero, 175 / D 20024 Garbagnate Milanese (MI). The data protection representative of operaLogica Srl within the European Economic Area is:

operaLogica Srl

Attn: Andrea Armellini

Via Montenero, 175 / D

20024 Garbagnate Milanese (MI)

E-mail:team@operalogica.com