Privacy Policy

 

 

Security and confidentiality of your personal data is our priority.

Through the website www.creativitysafe.com (the “Site“), CreativitySafe S.r.l. (“CreativitySafe”, “we”, “us”, “our”) collects some information related to you or to other data subjects (“Personal Data”).

According to Art. 13 and 14 of the General Data Protection Regulation (EU) 2016/679 (the “Regulation” or “GDPR”) and to the relevant applicable Italian data protection legislation, this privacy policy (“Policy”) is aimed at describing the processes of personal data carried out by CreativitySafe through the abovementioned Site.

Personal Data we may process refer to visitors (“Visitors”) and to users of the Site (“Users”) as well as to owner of the works (“Owners of the Works”) other than the Users and of whose registration a User requests from CreativitySafe (collectively, the “Data Subjects”).

 

Controller

With regards to this Policy and to the processes taken into consideration by it, the Controller (Art. 4(7) of the Regulation) is CreativitySafe S.r.l., with registered office in Italy, via Vivaio 6, 20122, Milan, Tax Code. – VAT NUMBER 10552740960.

What type of personal data we process

  • Personal Data provided by the Users

We collect some Personal Data about the Users when they decide to fill in the various fields on our Site. In particular, we collect and process Personal Data of the Users:

 

  1. When the Users register on the Site

Data processed: name, surname, date of birth, telephone number (landline and/or mobile), email address, domicile, postal address, company for which the User works.

Purpose and legal basis of the processing: Personal Data required when you register on the Site are marked with an asterisk. This data is necessary for us and is processed to allow us to proceed with the correct registration of the User on the Site.  The legal basis on which these types of processing rely is the consent of the User who requests to register. Refusal to provide us with such Personal Data will make it impossible for us to register you on the Site.

Retention period: Your Personal Data is kept for a period no longer than the necessary for the pursuit of the purposes for which it was collected. In particular, without prejudice to your right to autonomously cancel your account on the Site at any time, we will not retain your Personal Data for a period of more than 1 (one) year after registration, if you have not carried out any activity, unless this is necessary to comply with a legal obligation or to defend our rights before a judicial, administrative or other authority.

 

  1. When you purchase a service from our Site

Data processed: tax code, VAT number, bank details, in addition to the Personal Data provided to us at the time of the User’s registration on the Site.

Purpose and legal basis of the processing: on this occasion, the processing of your Personal Data will be carried out in order to proceed with the purchase, by you, of the various services that can be purchased through the Site. The legal basis for these further processing is the need to perform the contractual obligations arising from this purchase contract (including the related pre-contractual measures).

Retention period: which is 10 years from the last operation, unless this is necessary to comply with a legal obligation or to defend our rights before a judicial, administrative or other authority.

 

  1. When you decide to certify your work on the Site

Data processed: name, surname, tax code, e-mail address, identity card and any other personal data that may be contained in the work for which you request certification, if you decide to certify it in a standard way, which ultimately allows us to access the content of the file. We remind you that this is not necessary for the purpose of providing the Service and that you can always use the incognito mode, which does not allow us to access the content.

Purpose and legal basis of the processing: the processing of the abovementioned Personal Data is necessary in order to allow the certification of a work of a User on the Site. The legal basis for such processing is the need to perform the obligations arising from the contract concluded between CreativitySafe and the User in the context of which the certification of the work is requested.

Retention period: your Personal Data is kept for a period no longer than the necessary for the pursuit of the purposes for which it was collected. In particular, it will be kept for a period of no more than 1 (one) year from the termination of the subscription relationship between you and the Site with regard to the certification in question, unless this is necessary to comply with a legal obligation or to defend our rights before a judicial, administrative or other authority.

Special categories of personal data (“Sensitive Data”): the primary purpose of the Site is to protect the creativity and intellectual property rights of its Users. However, it may happen that a User requests the certification of a work or a document containing special categories of personal data, as defined by Art. 9 of the Regulation (e.g. data revealing racial origin, ethnicity, political opinions, religious beliefs, sexual orientation, etc.). CreativitySafe may only process such data with the specific consent of the data subject. It is understood that CreativitySafe invites the Users to certify their works with the incognito mode in the event that they contain Sensitive Data.

 

  1. When Users decide to register works on the Site on behalf of a different Owner of the Works

Data processed: name, surname, telephone number, e-mail address, postal addresses, domicile of the Owner of the Work, company for which the Owner of the Works performs his professional work. This data is requested from the User when, using his profile on the Site, he decides to register a work of a different Owner of the Works and refers to the said other Owner of the Works. By registering to the Site, the User will be solely responsible for ensuring that he has been legitimized by the other Owner of the Works to operate on his behalf also for what concern the processing of personal data.

Purpose and legal basis of the processing: The processing of such Personal Data is necessary in order to proceed with the registration on the Site of the works made by the data subject. Therefore, refusal to provide such Personal Data will make it impossible for CreativitySafe to proceed with the registration on the Site of such works.

Retention period: the Personal Data of the Owner of the Work are kept for a period no longer than the necessary for the pursuit of the purposes for which they are collected. In particular, they will be kept for a period of no more than 1 (one) year from the termination of the subscription relationship between the User and the Site with regard to the certification in question, unless this is necessary to comply with a legal obligation or to defend our rights before a judicial, administrative or other authority.

Special categories of personal data (“Sensitive Data”): the primary purpose of the Site is to protect the creativity and intellectual property rights of its Users. However, it may happen that a User requests the certification of a work or a document containing special categories of personal data, as defined by Art. 9 of the Regulation (e.g. data revealing racial origin, ethnicity, political opinions, religious beliefs, sexual orientation, etc.). CreativitySafe may only process such data with the specific consent of the data subject. It is understood that CreativitySafe invites the Users to certify their works with the incognito mode in the event that they contain Sensitive Data.

 

  1. When you decide to contact us

Data processed: if you decide to contact us at the email addresses or telephone numbers indicated on our Site or otherwise, you may provide us with other Personal Data. The optional, explicit and voluntary sending of electronic mail to the addresses indicated involves the subsequent acquisition of the sender’s address, necessary to respond to requests, and any other Personal Data included in the message.

Finalità del trattamento e base legale: these data, sent by you on a voluntary basis, will be used only for give a feedback to your request and therefore on the basis of your consent

Retention period: Your Personal Data will be kept for as long as is necessary to deal with your request.

 

  • Data collected during the navigation on the Site

When a Visitor visits a page of the Site, we collect the following navigation data in anonymized form:

  1. Technical information, including IP address, information about devices used by Visitors of the Site, browser and operating systems, etc.
  2. Information about your navigation on the Site, including URLs of the pages you visit and the activities you perform on the page (for example, with respect to the products you view or purches), dates and times of navigation, time spent on the Site, clickstream.

 

This information is collected for the proper functioning, management, maintenance and improvement of our Site, as well as to ensure that your navigation takes place safely and to be able to ascertain responsibility in the event of cyber-security violations.

In addition, we may process your navigation data with your consent, given through the acceptance of the cookie policy, also to allow you to take advantage of some of the interactive features of the Site, such as those with social networks (so-called plug-in social). With regard to the methods of protection of privacy and the processing of personal data collected by these social networks that allow the described interactions, please refer to the pages of individual social networks.

You are always free to decide whether to provide us with your navigation data. However, refusal to provide information necessary for navigation purposes may make it impossible to carry out activities closely related to navigation itself.

We retain such data only to the extent strictly necessary for the purposes for which it is collected.

Navigation data is collected through the use of cookies. To learn more about how cookies work and how to turn them on and off, please see our cookie policy.

 

Who do we share your data with?

To ensure that the processing of your Personal Data is as accurate as possible, CreativitySafe appointed certain data processor to whom your data may be disclosed. These subjects have been selected among professionals who ensure the implementation of appropriate technical and organizational measures, so that the processing will always be carried out in compliance with applicable legislation and ensuring the protection of your rights.

You may request the identity and contact details of the data controller(s) by contacting us as indicated in the “How to contact us” section of this Policy.

  • Police forces and supervisory and security bodies;
  • Judicial and supervisory authorities.

 

Transfer of personal data outside the EEA

For purposes strictly related to this Policy, the personal data of the Data Subjects may be transferred to countries outside the European Economic Area (“EEA“).

In order to guarantee the full protection of the rights and freedoms of the Data Subjects, these transfers will take place in accordance in full and strict compliance with the appropriate mechanisms and safeguards as per articles 44-50 of the Regulation.

In particular, in the event of transfers of personal data to the United States, CreativitySafe will ensure the protection of the rights and freedoms of the Data Subjects by applying standard contractual clauses approved by the EU Commission or through the mechanism of the EU-USA Privacy Shield.

How we protect your data

Il trattamento e la conservazione dei Dati Personali avverrà secondo le modalità e con gli strumenti idonei a garantire la sicurezza e la riservatezza dei dati stessi, in conformità di quanto previsto dal Regolamento. In particolare, saranno adottate adeguate misure tecniche, informatiche, organizzative, logistiche e procedurali di sicurezza, consentendo l’accesso alle sole persone incaricate del trattamento da parte del titolare o dei responsabili del trattamento designati dal titolare.

The processing and storage of Personal Data shall be carried out in accordance with the methods and instruments suitable to guarantee the security and confidentiality of the data, in compliance with the provisions of the Regulations. In particular, adequate technical, IT, organisational, logistical and procedural security measures will be adopted, allowing access only to the persons in charge of processing duly authorized by the controller or by the processors appointed by the data controller.

 

What are your rights and how to exercise them

In conformità con la normativa applicabile, ed in particolare con quanto stabilito dal Regolamento, i vostri diritti in relazione ai Dati Personali che trattiamo ai sensi della presente Informativa sono i seguenti:

  • Right to access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
  • Right to rectification: where you consider that your personal data are inaccurate or incomplete, you can require that such personal data be modified accordingly.
  • Right to erasure: without prejudice to the applicable law, you have the right to request the erasure of your Personal Data, to the extent that: (i) the data is no longer necessary for the purposes for which it was collected and processed; (ii) you revoke your consent to the processing; (iii) you object to the processing for direct marketing purposes or to the processing carried out for other purposes and there are no overriding legitimate reasons to continue with the processing; (iv) your data is processed unlawfully; (v) the erasure is required by law
  • Right to restriction of processing: you can request the restriction of the processing of your personal data.
  • Right to object: you can object to the processing of your personal data, on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
  • Right to withdraw your consent: where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.
  • Right to data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.

 

How to contact us

To exercise your rights and for any question or clarification on how your Personal Data are processed and used pursuant to this Policy, you can contact us by writing to privacy@creativitysafe.com or by phone (+39) 02 87 239 400. If you decide to contact us, all the data you provide will be processed exclusively for the purpose of providing prompt feedback and to ensure the proper management of your request.

 

Protection of your rights

In order to protect your rights and your Personal Data, you may at any time decide to lodge a complaint with the competent supervisory authority, i.e. the “Garante per la Protezione dei Dati Personali”, or to bring an action before the competent national courts.

Without prejudice to your rights to do so, we encourage you to always contact us to exercise your rights.

Privacy Policy

This Privacy Policy does not apply to any other third-party website that may be accessed through links on the Site.

 

Changes to this Policy

This Policy is subject to periodic updating. To this end, we report the last update date at the head of this Policy.

If you have already submitted your Personal Data, any change that substantially affects the processing of your Personal Data, will be communicated to you through the appropriate channels, always in way ensuring you the effective knowledge of the methods of processing, with the aim to guarantee the full transparency of the processing and a full and adequate protection of your rights.