Cube Srl, with offices in Via del Pratello No. 8, Bologna, Italy, publisher of the THE PLAN Journal and owner of the allied media, websites, applications, digital editions and dedicated platforms considers the protection of the personal data of its users / customers / and other parties (hereinafter called data subjects), whose data it collects, a priority concern. We hereby confirm that data subjects’ personal data are processed in full compliance with the provisions of Regulation EU 2016/679 (GDPR) and with the other rules governing the protection of personal data.

 

Data Controller

 

Cube S.r.l. in the person of Carlotta Zucchini, Legal Representative (VAT No. 02179681206)

Via del Pratello, No. 8, 40122 Bologna – Italy

Telephone: + 39 051/227634 – fax: + 39 051/220099

Email address of Data Controller: privacy@theplan.it

 

The personal data we collect

 

The Personal Data collected – both directly or through third parties - by Cube Srl are: Cookies, Usage Data, first name, family name, profession, street name and number, city/town, postal code, country, billing address, dispatching address, telephone number, fax number, email, password, username, company name, tax code, and VAT number. Cube Srl does not process sensitive data.

Full details of each type of data collected are provided in the relative sectors of this Privacy Policy or in the disclosures appearing at the head of the data collection sections. Personal Data may be freely supplied by the data subject or, in the case of Usage Data, collected automatically when the data subject uses our media.

Unless otherwise specified, all the data requested are mandatory. If the data subject declines to communicate these data, Cube Srl may be unable to supply the service requested. Those data indicated by Cube as optional may be withheld without jeopardy to the availability of the service requested or its operability. Should data subjects have any doubts on which data are mandatory, they should contact the Data Controller.

The eventual use of Cookies – or other tracking and profiling tools – by our websites or by data controllers of third party services used by our website, serves the purpose, unless otherwise indicated, of supplying the service requested by the data subject, as well as for the additional purposes described in this document and in the Cookie Policy: https://www.iubenda.com/privacy-policy/7910726/cookie-policy

In the event of the data subject providing third party data, he or she accepts full responsibility for the publication or sharing of the data on the media, and hereby confirms that he or she is authorized to communicate and disseminate such third party data, releasing the Data Controller of any third party liability.

 

Method and place of data processing

 

Processing method

The Data Controller adopts adequate technical security measures aimed at preventing the access, theft, cyber-attack, accidental loss, dissemination, alteration or unauthorized destruction of the Personal Data collected. These protection measures also include the use of pseudonymization and anonymization.

Data processing is carried out using computers and/or IT-enabled tools following organizational procedures and methods strictly related to the purposes indicated. In some cases, other persons charged with data processing may also have access to the data as well as the Data Controller. These include persons involved in the organization of the website (administrative, commercial, marketing, legal, system administrative personnel) or external third parties (third party technical services suppliers, mail carriers, hosting providers, IT companies, communication agencies) that, where necessary, are also appointed as Data Processors by the Data Controller. The updated list of such persons, where appointed, may always be obtained from the Data Controller on request.

 

The legal basis for processing

The Data Controller processes the Personal Data of data subjects under the following circumstances:

  • the data subject has given his/her consent to one or more specific data processing purposes;
  • processing is necessary in order to perform a contract with the data subject and/or comply with pre-contractual obligations;
  • processing is necessary to comply with a legal obligation incumbent upon the Data Controller;
  • processing is necessary to carry out a public interest duty or to exercise a public power entrusted to the Data Controller;
  • processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or third parties.

Consent is always required and must be expressly given by parents or legal guardians in the event of minors under the age of 16 accessing the website or the other media.

In any event, the Data Controller may be requested to supply further clarification on the legal basis for any data processing, and in particular, to indicate whether the data processing in question is carried out pursuant to statutory requirements, contractual provisions or in order to enter into an agreement.

 

Data processing location

 

Personal Data are processed at the operational headquarters of the Data Controller and in any other location in which the parties involved in the processing are located, currently within the European Union. For further information, please contact the Data Controller.

In the event of personal data being transferred for technical reasons outside of Italy and outside of the European Union, Cube Srl hereby undertakes to comply with the high security standards, basing any data transfer on:

-       European Commission adequacy decisions regarding the third party countries to which data are transferred;

-       adequate guarantees provided by the third party to which data are transferred;

-       adoption of the rules binding upon undertakings.

For further information on data transfer outside of Italy and on the legal bases for such transfer, please go to: http://www.garanteprivacy.it/

 

Period of storage

 

Personal data are processed and stored for the time necessary to fulfill the purposes for which they are collected.

  • Personal Data collected for purposes related to the performance of a contract between the Data Controller and the data subject shall be stored until said contract has been executed.
  • Personal Data collected for purposes connected with the legitimate interest of the Data Controller shall be stored as long as needed to fulfill such purpose, but in any event no longer than ten years. The data subject may obtain further information regarding the legitimate interest of the Data Controller in the appropriate sections of this document, or by contacting the Data Controller.

If data processing is conducted with the consent of the data subject, the Data Controller may store the Personal Data until such consent is withdrawn. In addition, the Data Controller may be obliged to retain Personal Data for a longer period whenever this is necessary in order to perform a legal obligation or on the order of an authority.

On expiry of the storage period, the Personal Data shall be erased. It follows that all data subject rights to access, erasure, rectification and portability of data may no longer be enforced.

 

Personal Data collection statement

 

The Personal Data of data subjects are collected to allow the Data Controller to provide its services and for the following purposes: statistical data collection, content display originating on external platforms, registration and authentication, address and email message management, contacting the data subject, advertising and hosting, backend infrastructure.

Data subjects can find further detailed information on the purposes of processing and on the specific Personal Data used for each purpose in the appropriate sections of this document.

 

Personal Data processing details

 

Personal Data are collected for the following purposes using the following services:

 

  •  To contact the data subject

Mailing list or newsletter (this website)

On registering his/her email with the mailing list or newsletter, the data subject’s email address is automatically included in a list of contacts that may receive email messages containing information, including commercial and promotional information pertinent to this website. The data subject’s email may also be added to the mailing list on the data subject registering with this website or making a purchase.

The Personal Data collected: first name, family name, profession, town/city, postal area code, country, email, telephone number.

 

  • • Address and email message management

This type of service enables management of a database of emails, telephone numbers and any other type of contact information used to communicate with the data subject.
These services may also allow data collection of information like the date and time messages are viewed by the data subject, the latter’s interaction with such messages, and whether the links included in the messages received have been entered.

 

ContactLab Outbound (ContactLab S.p.A.)

ContactLab is an address and email message management service provided by the company ContactLab S.p.A.

The Personal Data collected: email and telephone number.

Processing location: Italy – Privacy Policy.

 

  • • Hosting and backend infrastructure

These services host data and files enabling website operability, data and file distribution and make available ready-to-use infrastructure to allow specific functionalities on this website.
Since some of these services function through servers in different geographical locations, it is not possible to determine the exact location at which Personal Data are stored.

 

• ArubaCloud (Aruba S.p.A.)

 

ArubaCloud is a hosting service provided by the company Aruba S.p.A.

Personal Data collected: various data typologies depending on the specific provisions of the service’s Privacy Policy.

Data processing location: Italy – Privacy Policy.

 

  • • Advertising

These services enable the data subject’s Personal Data to be used for commercial and diverse other advertising communications, such as banners, also in relation to the data subject’s interests.
This does not mean that all the Personal Data are used for this purpose. Data and conditions of use are indicated in greater detail below.

Some of the services indicated below may use Cookies to identify the data subject, or to apply behavioral retargeting techniques, i.e. display personalized advertising announcements in line with the interests and behavioral patterns of the data subject as detected also beyond this website. For more information on this point, please consult the Privacy Policies of the respective services.

 

Smart AdServer (Smart AdServer SA)

Smart AdServer is an advertising service provided by the company Smart AdServer SA.

Personal Data collected: Cookies and Usage Data.

Processing location: France – Privacy PolicyOpt Out.

 

Adform (Adform)

Adform is an advertising service provided by the company Adform.

Personal Data collected: Cookies and Usage Data.

Processing location: Denmark – Privacy Policy.

 

  • • Registration and authentication

On registering or authenticating, the data subject consents to the application that identifies him or her and allows the data subject to access dedicated services.
As indicated below, registration and authentication services may be provided with third party assistance. In this event, the application may have access to certain data stored by the third party registration and identification service.

 

Direct registration (this website)

 

The data subject registers by filling in the registration form, supplying this website with his/her Personal Data.

Personal Data collection: first name, family name, address, street number, town/city, province/region, country, company name, billing address, dispatching address, telephone number, fax number, email, tax code, VAT number, username, password, profession, and various data typologies.

 

  • • Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data, keeping track of data subjects’ behavioral patterns.

 

Google Analytics (Google Inc.)

 

Google Analytics is an advertising service provided by the company Google Inc. (“Google”). Google uses the Personal Data collected to track and examine the use of this website, and compile reports, which are shared with the other services developed by Google.
Google may use Personal Data to contextualize and personalize the advertisements released by its own advertising network.

Personal Data collected: Cookies and Usage Data.

Processing location: USA – Privacy PolicyOpt Out.

 

Directly collected statistics (this website)

 

This website uses an internal statistics system with no involvement of third parties.

Personal Data collected: Cookies and Usage Data.

 

ScorecardResearch (ScorecardResearch)

 

ScorecardResearch is an advertising service provided by the company Full Circle Studies, Inc.

Personal Data collected: Cookies and Usage Data.

Processing location: USA – Privacy PolicyOpt Out.

 

  • • Display of content from external platforms

These services allow pageviews of and interaction with content hosted on external platforms directly on the pages of this website.
If a service of this kind is installed, it is possible that, even if the service is not used by the data subject, it will nonetheless collect traffic data regarding the pages on which it is installed.

 

Fonts.com Web Fonts (Monotype Imaging Holdings Inc.)

 

Fonts.com Web Fonts is a service providing display of web fonts managed by Monotype Imaging Holdings Inc. allowing this website to integrate the content into its own pages.

Personal Data collected: Usage Data and various data typologies depending on the provisions of the specific service provider’s Privacy Policy.

Processing location: USA – Privacy Policy.

 

Widget Video YouTube (Google Inc.)

YouTube is a video content display service managed by Google Inc. allowing this website to include Widget Video YouTube content on its website pages.

Personal Data collected: Cookies and Usage Data.

Processing location: USA – Privacy Policy.

 

Video Vimeo (Vimeo, LLC)

Vimeo is a video content display service managed by Vimeo, LLC, allowing this website to include Vimeo content on its website pages.

Personal Data collected: Cookies and Usage Data.

Processing location: USA – Privacy Policy.

 

Widget Google Maps (Google Inc.)

Google Maps is a video content display service managed by Google Inc. allowing this website to include Widget Google Maps content on its website pages.

Personal Data collected: Cookies and Usage Data.

Processing location: USA – Privacy Policy.

 

Further information on Personal Data

 

  • • Online sale of goods and services

The Personal Data collected are used to deliver services to the data subject or for the sale of products and their eventual delivery.

The Personal Data collected to allow credit card payment will depend on the payment system employed (Paypal, Alipay). These systems guarantee the anonymization of data processing in compliance with the strictest data protection standards.

https://www.paypal.com/it/webapps/mpp/ua/privacy-full

https://intl.alipay.com/ihome/help/agreements/detail.htm?agreement=AlipayPrivacyPolicy

 

Data subject rights: Data subjects may exercise the following rights at any time:

  • • withdraw consent at any time. Data subjects may withdraw consent previously granted to process their Personal Data.
  • • object to the processing of their Personal Data. Data subjects may object to their Personal Data being processed, when processing takes place on a legal basis other than consent. Further details on the right to object are given in the section below.
  • • obtain access to their Personal Data. Data subjects are entitled to obtain information on certain aspects of the processing of their Personal Data by the Data Controller, and to receive a copy of the processed data.
  • • verify and request rectification. Data subjects are entitled to verify the correctness of their Personal Data and request they be updated or corrected. 

  • • restrict processing.  Data subjects may request restriction of the processing of their Personal data. In this case, the Data Controller shall process the data subject’s data only for the specific purpose for which they are supplied, and shall not store the data subject’s data.
  • • erase or remove Personal Data. Data subjects may request the erasure of their Personal Data by the Data Controller.
  • • receive Personal Data or have them transferred to another Data Controller. Data subjects are entitled to receive their Personal Data in a commonly used structured format readable by an automatic device and, where technically feasible, obtain their transfer without impediment to another Data Controller.
  • • lodge a complaint. Data subjects may lodge a complaint with the competent personal data protection supervisory authority or take legal action.

 

Details of the right to object

 

Data subjects may, at any time, object to the processing of their Personal Data when such processing is carried out without their consent, provided detailed reasons are given by data subjects for the objection to data processing. Cube Srl does not carry out profiling activities without the consent of the data subject.

 

How to exercise data-subject rights

 

Data subjects can exercise their rights simply by contacting the Data Controller in one of the following ways:

1)    writing to Cube Srl – Via del Pratello, No. 8 – 40122 Bologna, Italy

2)    sending an email to: privacy@theplan.it

Requests will be answered in writing and complied with at no charge by the Data Controller as early as possible and in any event within a month of the request being received.

 

 

Cookie Policy

This website uses Cookies. To find out more and obtain more detailed information, the data subject should consult the Cookie Policy.

 

Further information on data processing

 

Legal action

 

The data subject’s Personal Data may be used in a court of law or in the preparatory phase before eventual legal action as a means of defense against illegal use by the data subject of this website or of the allied services.
The data subject hereby confirms he/she is fully cognizant of the fact that the Data Controller may be obliged to reveal his/her Personal Data at the request of a public authority.

 

Specific note

 

At the request of the data subject, this website may, in addition to the information contained in this Privacy Policy, provide the data subject with additional pertinent information on specific services or on the collection and processing of Personal Data.

 

System logs and maintenance

 

This website and eventual third party services used by our website may, for operational and maintenance purposes, collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the IP address of the data subject.

 

Information not contained in this Privacy Policy

 

Further information concerning the processing of Personal Data may be requested of the Data Controller at any time at the contact addresses given above.

 

“Do Not Track” requests

 

This website does not support “Do Not Track” requests.
To find out whether any of the third-party services support this function, data subjects are invited to consult the Privacy Policy of the services listed above. 

 

Amendments to this Privacy Policy

 

The Data Controller reserves the right to amend this Privacy Policy at any time, posting notification of any changes on this website, and also, where technically and legally feasible, notifying data subjects through one of the contact indications available to the Data Controller. Data subjects are therefore strongly recommended to check this page frequently, taking note of the date of the last modification listed at the bottom of the page.

Should the amendments impact any processing activities carried out only with data-subject consent, the Data Controller shall proceed to once more obtain, where necessary, the required consent from the data subject.

 

Definitions and legal references

 

Personal Data (or Data)

 

Personal Data are any information that, directly or indirectly, and also in connection with any other kind of information, including a personal identification number, that allows a natural person to be identified, or makes him/her identifiable.

 

Usage Data

 

Usage data is information collected automatically through this application (or by third-party services employed by this application) and may include: IP addresses or domain names of the computers utilized by data subjects who use this application, URI addresses (Uniform Resource Identifier), the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and operating system used by the data subject, visit time details (e.g., the time spent on each page within the application) and the path followed within the application, with special reference to the sequence of pages visited, as well as other parameters of the device operating system and/or the data subject’s IT environment.

 

Data subject

 

The natural person to whom the Personal Data refer, and the user of Cube Srl media.

 

Data Processor (or Data Handler)

 

The natural or legal person, public authority, agency or other body processing Personal Data on behalf of the Data Controller, as described in this Privacy Policy.

 

Data Controller (or Owner)

 

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing Personal Data, and the tools to be adopted, including the security measures to safeguard the functioning and use of this website. Unless specified herewith otherwise, the Data Controller is the Owner of this website.

 

This website (or this application)

 

 

The hardware or software by which the data subject’s Personal Data are collected.

 

Service

 

The service provided by this website as described in the relative terms and conditions (if available) and on this site/application.

 

European Union (UE)

 

Unless otherwise specified, any reference made in this document to the European Union includes all current members of the European Union and the European Economic Area.

 

Cookies

 

Cookies are small pieces of information stored in the data subject’s device. Cookies are the subject of a dedicated Privacy Policy: https://www.iubenda.com/privacy-policy/7910726/cookie-policy

 

Legal information

 

This privacy statement has been prepared in compliance with EU Regulation (GDPR) 2016/679 and with the other provisions applicable to personal data protection.

Unless otherwise specified, this Privacy Policy applies to all Cube Srl media, websites, applications, digital journals and dedicated platforms.

 

Last updated: 25 May 2018

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