Information to Data Subjects – Privacy & Cookie Policy of the Website
www.ismartframe.com
Art. 13 and seq. UK General Data Protection Regulation no. 2016/679 (“UK GDPR”)
Introduction:
scope of this privacy & cookie policy		   Dear User,
when you access and navigate on this website (hereinafter ‘Website’) some of your personal data is acquired, stored, and managed (in technical terms ‘processed’) through the device you are using, also by analyzing and saving your IP address, browsing data, ‘cookies’ and other online identifiers such as ‘pixels’.

In light of these processing activities, in compliance with the applicable legislation that requires the protection, confidentiality and security obligations on your data, Aritmetika Ltd clarifies below the purposes and means defined in its capacity as Data Controller.
Data Controller   Data processing operations will be performed as Data Controller by Aritmetika Ltd with legal seat in Highlands House Basingstoke Road Spencers Wood, Reading (Berkshire) RG7 1NT – England (UK) VAT no. 12427440 that can be contacted at the following addresses:
  • by writing an e-mail to privacy@aritmetika.net
  • by ordinary mail, at the address of the legal seat as provided above.
Categories of data processed  

The categories of data processed through the Website are:

• information related to the User’s browsing activities, including the so-called online identifiers and data related to the device in use * ;

• personal identification data and contact data (i.e. name, surname, e-mail address, physical address and telephone number) in case of use of the Website functionalities *;

• other categories of data, in case of further implementation of purposes on the Website.
Purposes, legal basis and data retention periods   Purposes Legal basis Data retention period
  User access to the pages of the Website and to its
functionality		 performance of pre-contractual and contractual activities For the duration the User remains on the Website, and in any case for a maximum of 24 months after it.
  Feedback to contact requests or information inquiries sent by the user performance of pre-contractual and contractual activities For a maximum of 5 years from the last interaction between the user and the Data Controller.
  User interactions with tools implemented by the Data Controller, such as the “Schedule a Meeting” tool performance of pre-contractual and contractual activities 12 months after the positive conclusion of the interaction with the User.
  Analysis of the usage statistics, improvement of the functionality of the Website and presentation of products and services to the User User consent except – in some limited cases – exercise of the legitimate interest of the Data Controller, aimed at improving its products and services Until the expiry of the online ID (cookie or other technology as stored), save for User’s requests of cancellation and/or anonymization activities.

Other information on how we process personal data

 

   If the User wish to receive further information about the balance between the legitimate interests pursued by the Data Controller and the fundamental rights and freedoms of the natural person, he/she can contact the Data Controller at the addresses indicated, and in particular at the e-mail address provided, having the right to receive adequate feedback as soon as possible and in any case within the time required by law.
In the event of litigation with the User or with third parties, or control of the competent Authorities, the conservation may be extended until the expiry of the last applicable prescription period.
The User’s personal data will not be disseminated in any way, except for the acquisition of express and prior consent or within the limits of what is provided for or imposed by law.

Consequences of failure to provide data

 

   The provision of personal data marked with an asterisk (*) is mandatory: not providing such data makes it impossible to proceed with the related processing.
The provision of other personal data is optional: failure to provide such additional data may make it impossible to access all or part of the Website’s functions or characteristics.

Automated decision-making processes

 

  

With the expression “automated decision-making processes” the legislation indicates (art. 22 GDPR) “any form of automated processing of personal data” that it uses to evaluate certain aspects of the person, and in particular “to analyze or predict (…) the professional performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movements” of the user in their capacity as ” Data Subject”.

The Website does not process any personal data through automated decision-making processes as described above, except where expressly indicated and based on User’s express and informed consent.

Categories of subjects that process data on behalf of the Data Controller

 

  

Within the limits of the obligations, tasks or purposes indicated above, personal data may be made available and / or communicated to:

– employees and / or collaborators of the Data Controller;

– other third parties who provide management, maintenance or intervention services on the Site and / or on other tools used by the Data Controller;

– Judicial, administrative and / or public security authorities.

The complete list of Data Processors and other third parties to whom the data are made available and / or communicated can be requested from the Data Controller at any time, at the indicated references.

Transfer of data outside the European Economic Area

 

   Personal data shall be transferred to countries outside the European Economic Area for technical purposes, in any case to subjects based in countries recognized as “adequate” by the European Commission or that have stipulated specific Standard Contractual Clauses based on the text approved by the European Commission. The Data Controller undertakes to implement additional safeguard if needed.
Rights of the Data Subject  

The User, as a “Data Subject” according to the UK GDPR, can at any time exercise the rights attributed to him by the Regulation n.2016/679.

In particular, the User has the right to:

– access his/her personal data;

– obtain the correction or cancellation of the same or the limitation of the processing that concerns him/her;

– oppose the processing, in case the Data Controller exercises its legitimate interest;

– obtain his/her data portability, where provided by the law;

– withdraw consent, where provided: the withdrawal of consent does not affect the lawfulness of the processing based on the consent given before the revocation;

– lodge a complaint with the supervisory authority.

For the United Kingdom (UK) – as the Data Controller’s home state – the supervisory authority is the “Information Commissioner’s Office” or “ICO”, based in London (England) (www.ico.org.uk).

The exercise of the aforementioned rights can take place by sending a request to the Data Controller’s references and in particular to the e-mail address indicated above.
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Last update on: 9th February 2023