Subject matter of the processing

When you use our services, you agree that our company may collect some of your personal information. This page is intended to inform you as to what data we collect, why and how we use it.

We process two types of data:

1. (a) data provided by the Data Subject/User (herein referred to as "you" or "User");
2. b) data that we collect automatically.

a) Data supplied by the User

If you are a private individual

If you are a private individual, when you register, we ask you to provide us with some data that are needed in order to use our services.

This is, for example, the data we ask you for:

• address, e-mail and password;
• name
• date of birth
• gender
• reference locality/town/city
• telephone number
• bank account number (IBAN)

Third-party data

If you provide the personal data of third parties, such as your family members or friends, you must be sure that these parties have been properly informed and have consented to the processing of such data in the manner described in this information notice.

Data of minors under 18 yrs

This site and the services of the Data Controller are not intended for those under 18 years, and the Data Controller does not intentionally collect personal information relating to minors. You must not therefore submit any personal data to us or register on our site, and in any case we do not assume responsibility for any false and/or misleading statements you provide. If we become aware of the existence of untrue statements, we will immediately delete all personal data acquired.

If you are a professional

If you are a professional, when you create a professional account you will be asked to provide us with some data:

• company name, VAT number, contact name, e-mail address and telephone number;
• professional category and full address.

b) Data that are acquired automatically

We collect the following data through the services you use:

• Technical data: e.g. IP address, browser type, information about your computer, information about the current (approximate) location of the device you are using;
• the data collected use cookies or similar technologies: for more information, please visit the relevant section.

What we use your data for

We use your data to provide you access to our service and its provision, including:

• registration and creation of the reserved area
• notices regarding service provision
• messages between users
• contact with the SWITCHBOARD
• review of communications, moderation or removal of content and prevention of fraud
• activities of an administrative, financial or accounting nature, such as those relating to the purchase of services against payment and possible debt recovery

Such processing is necessary in order to correctly provide escrowitalia.com's services to the users who commission them.

How we use the collected data

We also use your data to improve and implement the service, through the following processing activities:

• tracking of your (approximate) current position to facilitate the use of certain functions of the service
• communications relating to services similar to those you use
• market research, voluntary surveys and user-satisfaction surveys

Such processing is based on the legitimate interest of the Data Controller, and you may object at any time.

If you have expressly given us your consent, we use the collected data to inform you about promotional activities that may be of interest to you.

In particular, we use them to:

• communicate promotional, commercial and advertising activities on events, initiatives or partnerships of escrowitalia.com, by e-mail, SMS or push notifications; only if you are a professional, by phone calls through an operator, customer-care service consisting in the offer of dedicated services;
• carry out analysis and reporting activities related to promotional communication systems, such as the detection of the number of open e-mails, clicks made on links within the communication, the type of device used to read the communication and its operating system.

The provision of personal data is mandatory only for the processing necessary for the provision of services offered by escrowitali.com (refusal to provide the service for service-provision purposes makes it impossible to use the service), but is optional for promotional purposes and profiling and refusal to give consent does not have a negative impact on the provision of the service offered within the website www.escrowitalia.com and its applications.

Data Controller

The Data Controller is Escrow S.r.l. in person of its pro tempore legal representative, with registered address in Milan (Italy) in Via , , Tax/VAT Code.

The Data Controller avails itself of data processors for the purposes specified in point no.1, and a Data Protection Officer (DPO) to supervise the protection of personal data.

DPO and contact information

The designated Data Protection Officer, pursuant to Art. 37 of the GDPR, is Mauro Zagato.

We remind you that you can, at any time, contact the DPO and submit any questions or requests relating to your personal data and respect for your privacy by writing to: info@escrowitalia.it

Subjects to whom personal data may be communicated

The data collected as part of the service may be communicated to:

• companies that perform functions closely connected and instrumental to the operation - also technical - of escrowitali.com's services such as, for example, suppliers who provide services aimed at revising and checking ads, suppliers of direct marketing and customer-care services, companies that provide archiving, administrative, payment and invoicing services, and associated companies that provide technical components for the provision of certain functions of the service
• administrative and judicial bodies and authorities as per legal obligations

Your personal data may be transfer outside the European Union for processing by some of our service providers. In this case, we ensure that such transfers are carried out in compliance with current law and that a suitable level of protection of personal data is guaranteed, based on an adequacy decision, on standard clauses defined by the European Commission, and within the limits and under the conditions set out in Articles 44 et seq. of EU Regulation 2016/679.

Under no circumstances do we transfer or sell personal data to third parties.

Access to your reserved area and revocation of consent

You can, at any time, view your personal data in your private area. Enter your account and click on the "Reserved Area" section.

Remember that you can revoke your consent at any time by accessing your reserved area and removing the relevant flag.

To export your personal data (takeout) or request its cancellation, you can send a request to the e-mail address: info@escrowitalia.it from the e-mail address with which you registered on our site.

Your personal data will be exported within 30 days or, if the export should prove particularly complex, within three months.

Cancellations will be made within the specified technical timescales, and in accordance with the storage period set out in the point below.

Exercising of rights

Any natural person who uses our service can:

• obtain from the Data Controller, at any time, information about the existence of their personal data, the origin of the same, the purposes and methods of processing and, if any, obtain access to personal data and information referred to in Article 15 of the GDPR
"
• request the updating, rectification, integration, cancellation, limitation of data processing in the event that one of the conditions laid down in Article 18 of the GDPR is met, the transformation into anonymous form or blocking of personal data processed in violation of the law, including those data the retention of which is unnecessary in relation to the purposes for which the data were collected and/or subsequently processed
"
• oppose, in whole or in part, for legitimate reasons, the processing of data, even if pertinent to the purpose of collecting and processing personal data for purposes of commercial information or sending advertising materials or direct selling or for carrying out market research or commercial communication; users may also revoke consent at any time without prejudice to the lawfulness of processing based on consent given prior to revocation
• receive their personal data provided knowingly and actively or through the use of the service, in a format that is structured, commonly-used and readable by an automatic device, and transmit them to another data controller without hindrance
• lodge a complaint with the Italian Data Protection Authority

We remind you that, for any question or request regarding your personal data and the respecting of your privacy, you can write to the e-mail address: info@escrowitalia.it

Security

The Data Controller has adopted a wide variety of security measures to protect your data against the risk of loss, misuse or alteration. In particular, the Data Controller has adopted the measures set forth in Articles 32-34 of the Privacy Code and Article 32 of the GDPR. It uses, where necessary for more secure communications, the data encryption technologies established by the AES standards (BCCrypt) and protected data transmission protocols known as HL7 and HTTPS.

Data retention and period

Personal data will be stored on paper and/or electronically/digitally for the time strictly necessary to fulfil the purposes set out in point 1, in compliance with your privacy and applicable laws.

In the case of active users, user-generated content will be stored for 36 months for reasons of security, prevention and moderation of content and/or conduct contrary to escrowitalia.com's service conditions and contractual conditions in order to ensure a better quality of service also in collaboration with the Authorities.

For analysis purposes aimed at developing and improving the service, the user's personal data may be subject to the same storage period.

For direct marketing and profiling purposes, we retain your data for a maximum of 24 months and 12 months, respectively, as required by applicable law.

Invoices, accounting documents and transaction data are retained for 11 years in accordance with the law (including tax obligations).

In the case of exercising the right to be forgotten through a request for express cancellation of personal data processed by the Data Controller, please note that such data will be kept in a protected form and with limited access solely for purposes of investigation and prosecution of crime, for a period not exceeding 12 months from the date of the request and subsequently will be deleted safely or rendered irreversibly-anonymous.

Finally, we remind you that for the same purposes, the data relating to telematic traffic, excluding the contents of communications, will be kept for a period not exceeding 6 years from the date of communication, pursuant to Art. 24 of Law No. 167/2017, which implemented the EU Directive 2017/541 on anti-terrorism.

If you do not take any active action (e.g. browsing, searching and/or any other way of using the service) on escrowitalia.com for a period of 27 months, you will be classified as an inactive user and your personal data will be automatically deleted.

The data are collected by the subjects indicated in this information notice according to the indications of the reference legislation, with particular reference to the security measures provided for by the GDPR (Art. 32) for their processing by computer, manual and automated tools and with a logic strictly related to the purposes indicated, and in any case in such a way as to ensure the security and confidentiality of the data.

In compliance with the applicable regulations, an anti-spam system is in place for communications between users. The data entered may be verified for the sole purpose of identifying illegal activities or content not in accordance with the General Conditions of Service, but will not be processed or communicated for commercial or promotional purposes.

Further information

This information notice may be subject to change. If substantial changes are made to the use of user data by the Data Controller, the latter will notify the User by publishing them with the greatest evidence on its pages or by alternative or similar means. In any case, we recommend that you check this information notice regularly and always refer to the latest version.