1. Data Controller
Thrive-O S.r.l.
Via Mameli, 23/25 – 21049 Tradate
VAT no. IT 04032170120
Privacy requests: privacy request form
2. Purposes of the processing
Your personal data will be processed exclusively for the following purposes:
- Main purpose: management of the communications relating to the request made through the newsletter subscription form;
- Sending the newsletter: information and updates about our services and material reserved for subscribers, at most one email a month;
- Service communications: sending of information, updates and replies related to your specific request, and any contact by Thrive-O.
3. Types of Data Collected
Through the subscription form we collect your email address and your name (if the form asks for it), needed to provide you with the information requested and to maintain the communication relating to the service. We also collect the proof of your consent: text shown, version, date and time of the subscription and of the confirmation, version of the notice. We do not keep your IP address.
4. Legal Basis of the Processing
The processing is based on your free and informed consent (art. 6, letter a of the GDPR), given by filling in the form and confirmed with the link we send you by email (double opt-in). Until you confirm, no newsletter is sent.
5. How the Data is Processed
The data will be processed with computer and/or telematic tools, with organisational methods and logic strictly related to the purposes indicated. The mailing service (Listmonk, free software) runs on our servers, on a private network, and is not exposed to the Internet. The security measures provided by the GDPR will be adopted to prevent loss of data, unlawful or incorrect use and unauthorised access.
6. Data Retention
Your personal data will be kept indefinitely, until you ask for deletion, which you can do from the preferences area, unless the law requires a longer retention. If you only unsubscribe, with the link in every communication sent, your record (email address, name and proof of consent) stays marked as unsubscribed, so that you are not contacted again, until you ask for deletion; with deletion all the data, including the proof of consent, is removed.
7. Communication and Dissemination
The data will not be disseminated and may be communicated only to third parties in the cases provided for by law or when strictly necessary for the management of your request, with your explicit consent. The service runs on servers managed directly by Thrive-O and located in Italy; to send the emails we use, as data processor, Netsons S.r.l.
8. Your Rights
As a data subject, you have the right to:
- Access your personal data
- Rectify inaccurate data or complete it
- Erase the data (right to be forgotten) when the conditions provided by the GDPR are met
- Restrict the processing of the data
Objecting to the processing
You have the right to object to the processing of your personal data at any time, on grounds relating to your particular situation.
Data portability
You have the right to receive your personal data in a structured, commonly used and machine-readable format, and to transmit it to another controller, when technically possible. From the preferences area you can download your data.
Withdrawal of consent
You have the right to withdraw your consent to the processing of your personal data at any time, without affecting the lawfulness of the processing based on the consent given before the withdrawal.
To exercise these rights you can use the privacy request form, the link in every communication sent, or use the preferences area. The request goes directly to the person in charge, Fabio Cocchi.
9. Complaint to the Supervisory Authority
You have the right to lodge a complaint with the Garante per la protezione dei dati personali, the Italian Data Protection Authority (www.gpdp.it), if you believe that the processing of your personal data infringes the GDPR.
Privacy request
Fill in the form and choose the subject. The request goes directly to the person in charge, Fabio Cocchi.