Privacy policy

The purpose of this document (hereinafter the “Privacy Policy”) is to inform Users about personal data, understood as any information that allows the identification of a natural person (hereinafter the “Personal Data”), collected by the website https ://www.interlem.com/ (hereinafter “Website”).

The Data Controller, as subsequently identified, may modify or simply update, in whole or in part, this Information by informing Users. Changes and updates will be binding as soon as they are published on the website. The User is therefore invited to read the Privacy Policy each time they access the website. In case of non-acceptance of the changes made to the Privacy Policy, the User is required to cease using this website and may request the Data Controller to remove their Personal Data.

  1. Personal Data collected by the website

The Data Controller collects the following types of Personal Data:

  • Contact data and contents: are those Personal Data that the User voluntarily provides to the website during its use, such as for example personal data, contact details, access credentials for the services and/or products provided, personal interests and preferences and others personal content, etc.
  • Personal data collected by social media: Users may share data provided to social media with the website. The User has the right to control the Personal Data that the website can access through the privacy settings available on the social media in question. By associating accounts managed by social media with the website and authorizing the Owner to access such Personal Data, the User gives consent to their acquisition, processing and storage in accordance with this Privacy Policy. Failure by the User to provide Personal Data, for which there is a legal or contractual obligation or if they constitute a necessary requirement for the use of the service or for the conclusion of the contract, will make it impossible for the Owner to fully provide or part of its services. The User who communicates the Personal Data of third parties to the Owner is directly and exclusively responsible for their origin, collection, processing, communication or dissemination.
  1. Data and content acquired automatically during use of the website:
  • Technical data: the computer systems and software procedures used to operate this website may 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 Users, but which by its very nature could, through processing and association with Data held by third parties, allow Users to be identified. This category includes the IP addresses, or the domain names used by the Users who connect to the website, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained, etc.
  • Usage data: Personal Data relating to the use of the website by the User may also be collected, such as the pages visited, the actions performed, the functions and services used.
  • Geolocation data: the website may collect Personal Data on the User’s location which may be GNSS data (Global Navigation Satellite System, for example GPS data), in addition to data that identifies the nearest repeater, Wi-Fi hotspots and bluetooth, communicated when you enable location-based products or features.
  1. Personal data collected via cookies or similar technologies:

The website uses cookies, web beacons, unique identifiers and other similar technologies to collect Personal Data about the pages, links visited and other actions you take when using our services. They are stored before being re-transmitted on the next visit by the same User. The User can view the complete Cookie Policy at the following address: https://www.interlem.com/cookie-policy.

Purpose

The Personal Data collected may be used for the execution of contractual and pre-contractual obligations and for legal obligations as well as for the following purposes:

  1. Support and contact with the User: to respond to the User’s requests and help him in case of problems.
  2. Viewing content from external platforms: to allow the User to view and share content from social networks or other external platforms (e.g. YouTube, Facebook).
  3. Technical monitoring of the infrastructure for maintenance, troubleshooting and performance improvement: to identify and resolve any technical problems and improve performance.
  4. Traffic optimization and distribution: to more efficiently manage and improve the performance of the technical infrastructure.
  5. Management of User databases: to organize, access and modify User data.
  6. Monitoring, analysis and tracking of User behavior: to monitor and analyze how the User behaves on the website.
  7. Sending emails or newsletters and managing mailing lists: to contact the User with emails containing commercial and promotional information relating to the website.
  8. Market research and third-party surveys: to carry out market research and third-party surveys.
  9. Creation of third-party advertising campaigns: to create third-party advertising campaigns within the website.
  1. Treatment methods

The processing of Personal Data is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In some cases, subjects involved in the Data Controller’s organization (such as, for example, personnel management staff, sales area workers, system administrators, etc.) or external parties (such as IT companies, suppliers) may also have access to the Personal Data. of services, postal couriers, hosting providers, etc.). If necessary, these subjects may be appointed Data Processors by the Owner, as well as access the Personal Data of Users whenever necessary and will be contractually obliged to keep the Personal Data confidential. The updated list of Managers can be requested via email at info@interlem.com.

  1. Legal basis of the processing

The processing of Personal Data relating to the User is based on the following legal bases:

– the consent given by the User for one or more specific purposes;

– the processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures the processing is necessary to fulfill a legal obligation to which the Data Controller is subject

– the processing is necessary for the execution of a task of public interest or for the exercise of public powers vested in the Data Controller

– the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties

– the processing is necessary for the pursuit of a vital interest of the Data Controller or of third parties.

However, it is always possible to request the Data Controller to clarify the legal basis of each processing at info@interlem.com.

  1. Location

Personal Data is processed at the Owner’s operational offices and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller at the following email address info@interlem.com or at the following postal address Via Roma 35 – 10040, Rivalta di Torino (TO), Italy.

  1. Security measures

The Processing is carried out according to methods and with tools suitable to guarantee the security and confidentiality of the Personal Data, the Data Controller having adopted adequate technical and organizational measures which guarantee, and allow to demonstrate, that the Processing is carried out in compliance with the relevant legislation.

  1. Data retention period

Personal Data will be retained for the period of time necessary to fulfill the purposes for which they were collected. In particular, Personal Data will be retained for the entire duration of the contractual relationship, for the execution of the obligations inherent and consequent thereto, for compliance with applicable legal and regulatory obligations, as well as for own or third party defensive purposes. If the processing of Personal Data is based on the User’s consent, the Owner may retain the Personal Data until the consent is revoked. Personal Data may be retained for a longer period if necessary to comply with a legal obligation or by order of an authority. All Personal Data will be deleted or stored in a form that does not allow identification of the User within 30 days of the end of the retention period. Upon expiry of this deadline, the right of access, cancellation, rectification and the right to portability of Personal Data can no longer be exercised.

  1. Automated decision-making processes

The website uses automated decision-making processes that can produce legal effects for the person or significantly affect them and which operate according to these criteria: Email Marketing, Social Media Marketing.

  1. User Rights

Users can exercise certain rights with reference to Personal Data processed by the Owner. In particular, the User has the right to:

  • revoke consent at any time;
  • object to the processing of your Personal Data;
  • access your Personal Data; verify and request rectification;
  • obtain the limitation of treatment;
  • obtain the deletion of your Personal Data;
  • receive your Personal Data or have it transferred to another owner; lodge a complaint with the Personal Data Protection Supervisory Authority and/or take legal action. To exercise their rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are made free of charge and processed by the Data Controller as quickly as possible, in any case within 30 days.
  1. Data Controller

The Data Controller is INTERLEM S.A.S. di Andreone Carlo e C., with registered office in Via Roma 35 – 10040 Rivalta di Torino, Italy, Tax Code 09400450012 and VAT number 09400450012, e-mail address info@interlem.com, PEC address info@pec.interlem.com

Last update: 02/18/2022