Website Privacy Policy

Medas is constantly committed to protecting the online privacy of users of websites that refer or refer to this privacy statement (the “Site”). This document (the “Information”) has been prepared in order to allow you to understand how your Personal Data, as defined below, will be processed in the context of the use of the Site. The Information is intended to provide you with information necessary so that you can express explicit and informed consent to the treatments carried out through the Site, if you deem it appropriate.

In general, any information or Personal Data that you provide to Medas through the Site, or that is collected in any other way through the Site, in the context of the use of the services offered by Medas (the “Services”), as better defined in the following Paragraph 3, will be treated according to the internationally recognized principles of lawfulness, correctness, transparency, purpose limitation and retention, data minimization, accuracy, integrity and confidentiality.

INDEX

  1.    Holder of the treatment 
  2.    The personal data being processed
  3.    Name, contact details and other Personal Data
  4.    Special categories of personal data
  5.    Data provided voluntarily by the interested party and data of minors
  6.    Navigation data
  7.    Cookies
  8.    Purpose of the processing
  9.    Legal basis and mandatory or optional nature of the processing
  10.    Recipients of personal data
  11.    Transfers of personal data
  12.    Retention of personal data
  13.    Rights of the interested party
  14.    Changes

 

  1.    Data controller

Medas, as identified at the beginning of the Notice, is the Data Controller for all Personal Data that are processed through the Site

  1.    The personal data being processed

Following the navigation of the Site, we inform you that Medas will process your Personal Data, which may be constituted – also depending on your decisions on how to use the Services – by an identifier such as name, surname, tax code, province of residence, the telephone number, the e-mail address, an identification number such as the customer code, an online identifier or one or more characteristic elements of your physical, physiological, psychological, economic, cultural or social identity suitable to make you identified or identifiable (hereinafter only “Personal Data”).

Your Personal Data may be collected either because you voluntarily provide it (e.g. when you create your personal account in order to receive the Services offered by Medas) or simply by analyzing your behavior on the Site.

The Personal Data processed through the Site are as follows:

  1.    Name, contact details and other Personal Data

 

In various sections of the Site, in particular that relating to the creation of a personal account, you will be asked to enter information such as name, surname, tax code, province of residence, telephone number, e-mail address , the customer code, etc.

Furthermore, if you participate in surveys or any promotions that are made available through the Site, as well as when you communicate with Medas through the contacts you find on the Site or with the Customer Service, Medas may collect any additional information you decide to provide.

  1.    Special categories of personal data

 

Through the Site (e.g. through the Customer Service information request form) you could provide Medas with some information, which may contain Personal Data.

Since these fields are free, you may use them to communicate (voluntarily or not) some sensitive categories of Personal Data, such as data suitable for revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or sexual life or sexual orientation of the person.

Medas invites you not to send such Personal Data unless strictly necessary. Indeed, these special categories of Personal Data may be processed only with your explicit consent and in compliance with the pro tempore legislation in force. Medas therefore emphasizes the importance of giving your explicit consent to the processing of special categories of Personal Data, should you decide to share such information.

  1.    Data provided voluntarily by the interested party and data of minors

 

As already mentioned above, through the Site you are allowed to communicate information of various kinds to Medas, which may contain Personal Data of other people.

With respect to these hypotheses, you place yourself as an independent data controller, assuming all the obligations and responsibilities of the law. In this sense, you grant the widest indemnity on this point with respect to any dispute, claim, request for compensation for damage from treatment, etc. that it should reach Medas from third parties whose Personal Data have been processed through your use of the functions of the Site in violation of the applicable rules on the protection of personal data. In any case, if you provide or otherwise process Personal Data of third parties in the use of the Site, you guarantee from now – assuming all related responsibility – that this particular hypothesis of treatment is based on the consent of this third party concerned or on another suitable legal basis that legitimizes the processing of the information in question.

Medas reminds you that the use of the Site is reserved for people who have reached the age of 18. Where you are not of age Medas invites you to visit the Site in the company of a parent.

If through the methods indicated in the previous paragraph, you communicate to Medas Personal Data referable to a minor, you guarantee from now – assuming all related responsibility – that this particular hypothesis of treatment is based on the consent of the parental authority and / or representative legal status of the minor.

  1.    Navigation data

 

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) addresses 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 (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment. These data are used for the sole purpose of obtaining statistical information on the use of the Site and to check its correct functioning, to identify anomalies and / or abuses. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site or third parties: except for this possibility, the data on web contacts do not currently persist for more than 14 months.

  1.    Cookies

 

Definitions, characteristics and application of the legislation

Cookies are small text files that the sites visited by the user send and record on their computer or mobile device, to be then re-transmitted to the same sites on the next visit. Thanks to cookies, a site remembers the user’s actions and preferences (such as, for example, login data, the chosen language, font size, other display settings, etc.) so that they do not have to be indicated again. when the user returns to visit said site or browse from one page to another of it. Cookies, therefore, are used to perform computer authentication, session monitoring and storage of information regarding the activities of users who access a site and may also contain a unique identification code that allows you to keep track of the user’s navigation within. of the site itself for statistical or advertising purposes. While browsing a site, the user may also receive cookies from sites or web servers other than the one they are visiting on their computer (so-called “third-party” cookies).

Some operations could not be performed without the use of cookies, which in some cases are therefore technically necessary for the site to function itself.

There are various types of cookies, depending on their characteristics and functions, and these can remain on the user’s computer for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; CD. persistent cookies, which remain on the user’s equipment until a set deadline.

According to the applicable legislation, the user’s express consent is not always required for the use of cookies. In particular, “technical cookies”, ie those used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not usually require this consent. In other words, these are cookies that are essential for the operation of the site or necessary to perform activities requested by the user.

For “profiling cookies”, vice versa, ie those aimed at creating profiles relating to the user and used in order to send advertising messages in line with the preferences expressed by the same in the context of surfing the net, prior consent is usually required. of the user, insofar as it depends on the applicable legislation.

Types of cookies used by the Site and the possibility of (de-) selection

The Site uses the following cookies that can be de-selected, except for third-party cookies for which you will have to refer directly to the relative methods of selection and de-selection of the respective cookies, indicated by means of links:

  •      Technical navigation or session cookies, strictly necessary for the functioning of the Site or to allow you to take advantage of the content and services requested.
  •      Analytical cookies, which allow you to understand how the Site is used. These cookies do not collect information about your identity or any personal data. The information is treated in an aggregate and anonymous form.
  •      Functionality cookies, i.e. used to activate specific functions of the Site and a series of selected criteria (for example, the language) in order to improve the service rendered.
  •      Profiling cookies used in order to send advertising messages in line with the preferences expressed by you in the context of surfing the net.

 

Medas also uses third-party cookies, i.e. cookies from websites or web servers other than that of Medas, used for the purposes of said third parties, including profiling cookies. It should be noted that these third parties, listed below with the relative links to the privacy policies, are typically autonomous data controllers of the data collected through the cookies they serve, or act as Data Processors for Medas (i.e. they process Personal Data for account of Medas).

As regards the third parties that send cookies through the Site, below you will find the links to the respective privacy policies:

  •      Google (//policies.google.com/privacy?gl=IT&hl=it)
  •      Facebook (//www.facebook.com/privacy/explanation)
  •      Weborama (//weborama.com/e-privacy-2/)

 

– Cookies on the Site

In detail, the cookies sent by Medas through the Site are indicated below:

Name:  _ga

Value:

Domain: .medas-solutions.it

 

Name:  _gid

Value:   Domain: .medas-solutions.it

 

Name:

Value:   1

Domain: .medas-solutions.it

 

Cookie settings

Cookie settings

You can block or delete (in whole or in part) technical and functional cookies through the specific functions of your browser. However, we inform you that not authorizing technical cookies could make it impossible to use the Site, view its contents and use the related services.

The choices made in relation to the Site’s cookies will in turn be recorded in a specific cookie. This cookie may, however, in some circumstances not work properly: in such cases, we recommend that you delete unwanted cookies and inhibit their use even through the functionality of your browsers.

Your preferences regarding cookies will be reset if you use different devices or browsers to access the site.

How to view and modify cookies through the browser

You can authorize, block or delete (in whole or in part) cookies through the specific functions of your browser. For more information on how to set preferences on the use of cookies through the Browser, you can consult the relevant instructions:

  •      Internet Explorer
  •      Firefox
  •      Chrome
  •      Safari

 

You can also manage your choices regarding third-party cookies using online platforms such as AdChoice.

ATTENTION: by disabling technical and / or functional cookies, the Site may not be available for consultation or some services or certain functions of the Site may not be available or may not work properly and you may be forced to modify or manually enter some information or preferences each time you visit the site.

  1.   Purpose of the processing

Medas will use your Personal Data, collected through the Site, for the following purposes:

  •      allow you to access and register your personal account on the Site; verify your identity and help you, in case you lose or forget the login / password details of your personal account on the Site or provide you with any other Service you request “Provision of Services”)

 

  •      send you marketing communications, promotions and advertising, market research and surveys, by e-mail, sms, mms, app, traditional mail bot, telephone and / or through the official Medas accounts on social networks; as well as for marketing activities in a broad sense, including prize events, games and competitions, of products and / or services referable to Medas and / or to products and / or services of third parties (“Marketing”);

 

  •      send you marketing communications via email regarding products and services similar to those you purchased through the Site (“Soft Spam”);

 

  •      to create your profile through the use of profiling cookies, where accepted, thus collecting and analyzing information on the selections and choices you make on the Site; as well as your general activities on the Site when you are a registered user, therefore collecting information on any of your questions and navigation. This profile will be used to provide you with information on other products and / or services that Medas believes may be of interest to you and to show you advertisements that may be relevant to your tastes. All algorithms involved in this process are regularly tested to ensure that you are not offered products that you are not interested in (“Profiling”);

 

  •      fulfill legal obligations that require Medas to collect and / or further process certain types of Personal Data (“Compliance”);

 

  •      prevent or identify any abuse in the use of the Site, or any fraudulent activity and therefore allow Medas to protect itself in court (“Abuse / Fraud”).

 

  1.    Legal basis and mandatory or optional nature of the processing

The legal bases used by Medas to process your data, according to the purposes indicated in the previous Paragraph 3, are the following:

  •      Provision of the Service: processing for this purpose is necessary in order to be able to provide you with the Services and, therefore, for the execution of the contract with you. It is not mandatory to provide Medas with your Personal Data for this purpose, but otherwise it will not be possible to provide you with any Service.
  •      Marketing: the processing for this purpose is based on your consent. It is not mandatory to give your consent to Medas for this purpose and you are free to revoke it at any time without any consequence (except for the fact that you will no longer receive marketing communications from Medas). You can revoke your consent previously given by following the instructions in Paragraph 8 of this Notice.
  •      Soft Spam: the processing for this purpose is based on Medas’ interest in sending you marketing communications via email regarding products and services similar to those you have already purchased through the Site. You can stop receiving these communications, without any consequence for you. (besides the fact that you will no longer receive further communications of this kind from Medas) using the link at the bottom of each of these emails;
  •      Profiling: the processing for this purpose is based on your consent. It is not mandatory to give your consent to Medas for this purpose and you are free to revoke it at any time without any consequences (except for the inability to benefit from the customization of the commercial offers you will receive from Medas). You can revoke your consent previously given by following the instructions in Paragraph 8 of this Notice.

 

  •      Compliance: processing for this purpose is necessary for Medas in order to fulfill any legal obligations. When you provide Personal Data to Medas, they must be treated according to the applicable legislation, which could involve their conservation and communication to the Authorities for accounting, tax or other obligations.
  •      Abuse / Fraud: the information collected for this purpose will be used exclusively to prevent and / or identify any fraudulent activity or abuse in the use of the Site and therefore allow Medas to protect itself in court.

 

  1. Recipients of Personal Data

Your Personal Data may be shared with the subjects indicated below (the “Recipients”):

  •      subjects that typically act as data processors, that is: i) persons, companies or professional firms that provide assistance and consultancy to Medas in accounting, administrative, legal, tax, financial and credit recovery matters relating to the provision of Services;
  •      subjects with whom it is necessary to interact in order to provide the Services (for example suppliers of platforms for sending e-mails);
  •      subjects delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communication networks);
  •      persons authorised by Medas to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of Medas);
  •      companies of the Medas Group for internal administrative purposes;
  •      persons, entities or authorities to whom it is mandatory to disclose your Personal Data for compliance, abuse or fraud purposes, or by order of the authorities;

 

  1.  Transfers of Personal Data

Some Personal Data may be shared with recipients who may be located outside the European Economic Area. Medas ensures that the processing of Personal Data by these recipients is carried out in accordance with the applicable legislation. Indeed, transfers may be based on an adequacy decision or on Standard Contractual Clauses approved by the European Commission. Further information is available from Medas by writing to the addresses set out in Section 8 below.

  1. Retention of Personal Data

The Personal Data processed for the purpose of Providing the Services will be kept by Medas for the time strictly necessary for the aforementioned purpose (eg for the management of the contract with Medas). In any case, since such Personal Data are processed to provide you with the Services, Medas may keep them for a longer period, in particular as may be necessary in order to protect Medas’ interests from possible complaints relating to the Services.

Personal Data processed for Marketing purposes will be kept by Medas until you withdraw your consent. Once the consent has been revoked, Medas will no longer use your Personal Data for these purposes, but may still keep them, in particular as may be necessary in order to protect Medas’ interests from possible complaints based on such treatments.

Personal Data processed for Profiling purposes will be kept by Medas until you withdraw your consent. Once the consent has been revoked, Medas will no longer use your Personal Data for these purposes, but may still keep them, in particular as may be necessary in order to protect Medas’ interests from possible complaints based on such treatments.

The Personal Data processed for the purpose of Soft Spam will be kept by Medas until you object to such processing through the link at the bottom of each of the Soft Spam e-mails.

Personal Data processed for Compliance will be kept by Medas for the period provided for by specific legal obligations or by applicable legislation.

The Personal Data processed in order to prevent Abuse / Fraud will be kept by Medas for the time strictly necessary for the aforementioned purpose and therefore until the moment in which Medas will be required to keep them to protect itself in court or to communicate said data to the competent Authorities.

  1. Rights of the interested party

You have the right to ask Medas at any time:

  •      access to your Personal Data, (or a copy of such Personal Data), as well as further information on the treatments in progress on them;
  •      the correction or updating of your Personal Data processed by Medas, where they are incomplete or out of date;
  •      the deletion of your Personal Data from Medas databases;
  •      the limitation of the processing of your Personal Data by Medas;
  •      to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format

as well as you can:

  •      oppose the processing of your Personal Data by Medas (eg Soft Spam and Profiling);
  •      withdraw your consent for Marketing and Profiling purposes.

 

When requesting the Services, you may have selected which communication channels through which you want to be contacted for marketing purposes (i.e. e-mail, sms, mms, app, traditional mail bot, telephone and / or through the official accounts of Medas on social networks).

You will be able to withdraw your consent for Marketing relating to each of these communication channels through the methods indicated below.

You can also revoke the marketing consent sent by e-mail and stop receiving Soft Spam by using the appropriate link at the bottom of each e-mail received. The same method can be used to stop receiving the Medas newsletter, if you have requested it as a Service.

The consent to Profiling through cookies can be revoked through the methods indicated in the previous Paragraph 2.f.

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data) if you believe that the processing of your Personal Data is contrary to the legislation in force.

  1.     Changes

This privacy policy is effective from 11 October 2018.

Medas reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. Medas will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the Site. Medas therefore invites you to regularly visit this section to become aware of the most recent and updated version of the privacy policy in order to always be updated on the data. collected and on the use that Medas makes of them.