Ellycode S.r.l. (from now on, for the sake of brevity, “Ellycode”, or the “Company”, or “we”) informs you that your personal data acquired while browsing this site will be processed in accordance with the law on the protection of personal data.  

With this statement (pursuant to Article 13 of EU Regulation No. 679/2016) we provide you with the information regarding the methods used for the management and processing of your personal data, as a user who consults this site. 

1. Types of data collected, purposes and legal basis for the processing operations 

Browsing data 

The information technology systems and software procedures that enable the functionality of this site acquire, during their normal utilisation, certain personal data that is implicitly transmitted to the Company because of the use of internet communication protocols.  

This category of data includes:  

• the IP addresses or domain names of the computers used to access the site,  
• the MAC (Media Access Control) addresses,  
• the addresses in URI (Uniform Resource Identifier) notation 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 operating system and the user’s information technology environment.  

These data are used for the sole purposes of compiling anonymous statistical information on the use of the site and to check its correct functionality, and are deleted immediately after processing.  

The data may be used to ascertain liability in the event of cybercrimes that cause damage to the site. The legal basis that legitimises the processing of personal data for this purpose is set out in Article 6, section 1, letter b) of EU Regulation No. 679/2016 – i.e. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.  

The same data may also be used to ensure compliance with legal obligations or requests on the part of the judicial authorities. The legal basis that legitimises the processing of personal data for this purpose is set out in Article 6, section 1, letter c) of EU Regulation No. 679/2016 – i.e. processing is necessary to comply with a legal obligation to which the Data Controller is subject. 

Data that you supply voluntarily  

Should you send email messages to the email addresses found on the site, Ellycode may process your email address (as the sender) and any additional personal data contained in the message, in order to respond, again by email, to the requests you have submitted. The legal basis that legitimises the processing of personal data for this purpose is set out in Article 6, section 1, letter b) of EU Regulation No. 679/2016 – i.e. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.  

The same data may also be used to ensure compliance with legal obligations or requests from judicial authorities. The legal basis that legitimises the processing of personal data for this purpose is set out in Article 6, section 1, letter c) of EU Regulation No. 679/2016 – i.e. processing is necessary to comply with a legal obligation to which the Data Controller is subject. 

As the Data Subject, you are asked not to enter or send via the instruments provided on the site any “special categories of data”, “biometric data”, “genetic data”, “data concerning health” or “data relating to criminal convictions and offences” as defined by the current legislation. 

Should you provide such data, as the Data Subject, it will be immediately deleted. 

Cookies 

The site uses technical (session and browsing) cookies for the purposes of enabling the normal browsing and utilisation of the website (allowing, for example, authentication in order to access reserved areas) and analytical cookies for statistical purposes. For the complete information relating to the processing operations carried out on personal data through cookies, please see the full cookies statement, which can be reached on every page of the portal. 

1. Period of data storage 

Any of your personal data collected and processed as a result of you browsing this site will be stored for the entire period of delivery of the service and will be, in any case, deleted or rendered anonymous within 7 days.  

Any personal data that you send of your own volition through the tools of the site will be deleted after the requested service is delivered or a response is provided, and in any case within the maximum term of 15 days from the completion of said operations, with the exception of those data that are necessary to ensure compliance with fiscal, accounting and administrative regulations, or to comply with other legal obligations, and to document the operations carried out. 

1. Methods of processing 

Any personal data collected will be processed, retained and analysed using electronic tools and will be stored both in electronic format and in hard copy, organised into databases, and on any other appropriate type of media. 

Specific security measures are implemented to prevent the loss, illegal or unfair use of the data, or unauthorised access to them. 

The processing of your personal data carried out by Ellycode does not involve any automated decision-making. 

1. Disclosure of your personal data 

The disclosure of the browsing data is required in order to supply the requested service (browsing of the site) and it is, therefore, compulsory for that purpose. Failure/refusal on your part to provide your personal data will make it impossible for Ellycode to allow you to browse this site.  

The disclosure of your data for other purposes is optional: failure/refusal to provide your data for said other purposes will not have consequences for you but may make it impossible to provide you with the requested responses. 

1. Parties to which your personal data may be disclosed 

None of your personal data collected by the Company will be disclosed indiscriminately. However, said data may be communicated to: 

• those parties that have the right to access to your personal data to ensure compliance with legal and secondary and/or EU regulations (for example, to Authorities in the framework of judicial cooperation);  
• to the Data Controller’s own personnel; and also  
• to companies, associations or professional firms that provide services and operations on behalf of the Data Controller, operating as Data processors, in particular for the provision of ICT services (e.g. web hosting services), to ensure compliance with legal obligations, and for every other organisational and/or administrative requirement that is necessary to provide the requested services. 

The names of the parties, operating as Data processors, to which your personal data may be disclosed are shown in an up-to-date list that can be requested from Ellycode (through the contact information indicated at Point 8). 

1. Transfer of data outside the European Union or to international organisations 

Ellycode may transfer the personal data of the data subject to the USA to entities that operate as data controllers for the provision of digital services. This transfer is regulated by adequate guarantees and in particular is based on the Data Transfer Agreement concluded between the United States of America and the European Commission. To obtain a copy of the same, it is possible to send a request to the contacts indicated in point 8 of this information. 

1. Your rights as the Data Subject 

In relation to the aforementioned processing operations carried out on your personal data, you are entitled to exercise at all times those rights set out by EU Regulation No. 679/2016 (GDPR), including, for example, the right to be informed as to: 

• the origin of any personal data held that concerns you;  
• the purposes and methods of the processing operations;  
• the logic applied in the case of processing operations carried out using electronic instruments; the identification of the Data Controller, the Data Processors and the designated representative. 

As the Data Subject, you have the right to obtain: 

• access to the data and its updating, rectification or (where in your interest) completion;  
• the erasure, transformation into anonymous form or blocking of access to any data processed in breach of the law;  
• the limitation of the processing of those data that concern you, or to request the reduction of the purposes and/or methods for/with which your data are being processed to the Data Controller or the Data Processor. 

You can also request a copy of your data in a standard format (the so-called “Right to data portability”). 

As the Data Subject, you also have the right to object, at any time and at no cost, wholly or partially: 

• for legitimate reasons, to processing of your personal data, even if the processing operations are still relevant to the purpose for which the data were collected in the first place;  
• to processing of your personal data carried out pursuant to Article 6, Paragraph 1 of the GDPR, Letters e. (“processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”) or f. (“processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party”) including profiling on the basis of these provisions; 
• to processing of your personal data for the purposes of sending advertising or direct sales material or for the completion of market research or commercial communications (direct marketing), including any relevant profiling operations. 

You have the right to withdraw your consent for the processing operations when that consent is based on by Article 6, Paragraph 1, Letter a. (when “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”), or by Article 9, Paragraph 2, Letter a. (when “the data subject has given explicit consent to the processing of those personal data for one or more specified purposes”) of EU Regulation No. 679/2016, at any time, without affecting the lawfulness of processing based on consent before its withdrawal. 

Should you consider the processing operations to have been carried out in breach of current legislation, you have the right to lodge a complaint with a supervisory authority, specifically in the Member State in which you habitually reside or work, or the Member State where the alleged breach has taken place. The Italian supervisory authority can be contacted using the contact data on its own website. 

1. Data Controller – Contact data 

The Data Controller is Ellycode S.r.l. with its registered offices at Via Michelangelo n. 16, 80026 Casoria (NA), VAT no. 09406031212. 

The Company can also be contacted at the following email address: info@ellycode.com. 

To exercise the rights listed above, the data subject may make a request using the email address: info@ellycode.com.