In this Privacy Notice, we describe what we do with your data when you use https://agondigital.com/, obtain services or products from us, interact with us in relation to a contract, communicate with us or otherwise deal with us.
When appropriate we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, additional privacy notices, forms and other notices.
If you disclose data to us or share data with us about other individuals, such as family members, co-workers, etc., we assume that you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.
This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR»)..
In this document, we use, inter alia, the following terms:
A Personal data:
any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
B Data subject:
any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
C Controller/ Data Controller:
the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
D Data Protection Officer:
the natural or legal person who ensures that the company or organization is correctly protecting individuals’ personal data according to current legislation.
a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of that data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
H Consent of the data subject:
any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
I Restriction of processing:
the marking of stored personal data with the aim of limiting their processing in the future.
any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
L Third party:
a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Spettabile Agon Digital Srl
Viale Spartaco Lavagnini,7
Communication data: When you are in contact with us via the contact form, by email, telephone or chat, or by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication.
Agon Digital in the provision of its services does not collect nor store any personal data by ourselves. We work with a tracking platform in white label TradeDoubler For more info visit https://www.tradedoubler.com/it/privacy-policy/
We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data, anda registration data in relation to offers and services that you use.
The legal basis for the processing of personal data is explained as follows:
-Your consent, which you can express through the Contact Form established on the website.
According to Article 6 of the GDPR, processing shall be lawful only if and to the extent that at least one of the following applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract: for example, when processing operations are necessary for the supply of goods or to provide any other service. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services;
c) processing is necessary for compliance with a legal obligation to which the controller is subject and for which processing personal data is required, such as for the fulfillment of tax obligations;
d) processing is necessary in order to protect your vital interests or the ones of another natural person: for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party.
e) processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
The data will be processed using electronic tools suitable for guaranteeing security, in relation to the purposes for which they were collected, as well as to avoid unauthorized access by third parties and, in any case, in compliance with the provisions of national and European legislation.
In no case we use the data collected by us or by other third parties to determine your personal identity, and all data is processed anonymously. In particular, we use randomized user identification strings that are anonymous by design. IP addresses processed for technical delivery will be salted by the user agent string and stored in a hashed format, preventing any possibility of reconstruction.
The Site contains third party cookies by Tradedoubler. This Site sends your browser a cookie – a small piece of data stored on your computer’s hard drive. The purpose of the cookie is to improve your reading of and your search possibilities on our Site. This cookie is not personal data since neither Tradedoubler or any other party can identify you by this cookie number. It is just a unique randomly generated nuamber by Tradedoubler. If you are a registered Client (Advertiser or Publisher), the cookie will also manage and control your login and session on those parts of our Site that are only available to registered Clients. These session cookies are automatically deleted when you close your browser.
For further information visit: https://www.tradedoubler.com/it/privacy-policy/
We inform you of the possibility of exercising at any time the rights that are recognized by GDPR and data protection laws, reported as follows:
a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed.
b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority (Privacy Guarantor);
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
- Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
c) Right to rectification
According to Article 16 of the GDPR, each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
d) Right to erasure (right to be forgotten)
Each data subject shall have the right granted by Article 17 of the GDPR to obtain the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws consent to which the processing is based according to point (a) of Article 6.1 of the GDPR, point (a) of Article 9.2 of the GDPR, and where there is no other legal ground for the processing;
- the data subject objects to the processing pursuant to Article 21 of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 of the GDPR;
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8.1 of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Agon Digital, he/she may, at any time, contact any employee of the controller. The controller shall promptly ensure that the erasure request is complied with immediately. Where the controller has made personal data public and is obliged pursuant to Article 17.1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.
e) Right to obtain the portability of your data, according to Article 20 of the GDPR
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
f) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
g) Right to oppose data processing, according to the Article 21 of the GDPR
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Agon Digital shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.
If Agon Digital processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Agon Digital to the processing for direct marketing purposes, Agon Digital will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Agon Digital for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
h) Right to oppose an automated decision-making process relating to natural persons, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Agon Digital shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
Any request can be addressed to: email@example.com
In relation to our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and other purposes, we don’t disclose your personal data to third parties since we do not store any data, so we're not able to share anything.
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
Into its products, the controller has integrated components of Tradedoubler – Connect and Grow we're using their technology and platform to track traffic and events for our clients.
Tradedoubler’s advertisers, publishers, media agencies and other customers that from time to time provide Tradedoubler with personal data, as well as web surfers whose digital data is processed by Tradedoubler as part of its provision of services to its Clients (hereafter the “User/Users”), must be able to trust that data is processed by Tradedoubler in accordance with applicable privacy laws and regulations.