Privacy

A. PRIVACY POLICY

Regulation (EU) 2016/679 of the European Parliament on the protction of personal data

Brief introduction and premise

FIDAVO.com (www.fidavo.com) is a portal owned by FIDAVO LIMITED, based in Dublin, 1 Watermill Lawn, Dublin 5, D05 K738 (hereafter also, “FIDAVO LIMITED” or the “Company”).

FIDAVO LIMITED wanted to give life to the portal FIDAVO that represents a virtual “market“ intended to favor the encounter between the question and the offer of investigation services from primary and selected operators of the field.

Through FIDAVO, therefore, FIDAVO LIMITED mediates between the supply and demand of investigation services, making available to end users/customers their many years of experience in the field in order to select primary and reliable operators that offer their services through the FIDAVO portal.

This page describes how FIDAVO LIMITED, as Data Controller, collects and processes your personal data through the FIDAVO portal.

Very briefly, the FIDAVO portal allows the User to examine and evaluate different solutions of investigative services offered by stakeholders selected by FIDAVO LIMITED in order to identify the offer that best suits their needs.

The FIDAVO portal also offers the possibility to the registered User to be able to make a videocall fact-finding with the chosen operator in order to assess the subsequent mission of a formal assignment to the same operator.

Please note that the specific terms and conditions under which the survey services are to be conducted will be the subject of a separate and autonomous contract that will be signed between the User and the chosen operator, with respect to which FIDAVO LIMITED will remain completely unrelated.

We would like to focus on confidentiality, privacy and personal data protection of users represent our firm commitment.
In fact, we process your personal data with the utmost care and in accordance with the applicable laws on privacy and security (in particular the General Data Protection Regulation EU 679/2016) inspired by the principles of lawfulness, correctness, transparency, minimization and limitation of the data provided by the aforementioned legislation.

B. WHO IS THE DATA CONTROLLER?

The Data Controller of the personal data acquired and processed through the FIDAVO portal is FIDAVO LIMITED SRL, based in Dublin, 1 Watermill Lawn Dublin 5, D05 K738 (below also the “Data Controller”); e-mail: [email protected].

C. WHO IS THE DATA PROTECTION OFFICER?

In carrying out its tasks (ref. Art. 24 e Art. 37 Comma 1 of the Regulation UE 679/2016) the Data Controller has appointed the Data Protection Officer (DPO - Data Protection Officer). In this regard, Data Controller has been designated according to his professional skills, with special regard to the specific legislative expertize and data protection practices. The duties of Data Protection Officer are those indicated by Art. 39 of the Regulation. The contact details of the DPO are as follows: [email protected].

D. WHAT INFORMATION DO WE COLLECT AND PROCESS?

The data subject to processing by the Data Controller are personal and identifying informations (for example, name, surname, address, telephone and e-mail) - later, “personal data“ or even “data“ - communicated as necessary for the use of the services provided by the FIDAVO portal, as well as those spontaneously provided by the User.

E. FOR WHAT PURPOSES DO WE USE YOUR DATA?

The main purpose is to allow the User access to the FIDAVO portal and, therefore, the possibility to benefit from investigation services offered by industry operators through the same portal.

In particular, the operations carried out by the Data Controller involve the collection, storage and processing of personal data, for the following purposes:

1. make possible access and navigation on the FIDAVO portal;
2. provide the User with the benefit from investigation services offered by the operators of the sector through the FIDAVO portal;
3. subscription to the newsletter, to receive promotional and notices about the investigation services offered by the operators of the sector through the FIDAVO portal and/or in any case about the activities/ initiatives available through the same portal;
4. examination and study of the User’s interests to define its individual profile. This activity serves to send the User (if he has consented to receive our communications for advertising and commercial purposes) updates (including customized) on the activities/ services offered through the FIDAVO portal, in particular on new services/activities offered through the FIDAVO portal, surveys and/or opinions and other types of communication related to services/activities offered through the FIDAVO portal and for the development of statistical and commercial research studies that are in line with the User’s interests.

The provision and/or consent to the processing of personal data for the purposes referred to in the above letters a) and b) is necessary. In the absence of such consent, the FIDAVO portal will not be accessible, therefore, have the opportunity to take advantage of the investigation services offered by operators through of the same portal. The consent for such processing is expressed through the “flag“ of the appropriate box at the bottom of this Privacy Policy with the words “I consent to the processing of my personal data in order to access and use the investigation services offered by industry operators through the FIDAVO portal”.

The provision and/ or otherwise consent to the processing of data for marketing purposes referred to letter c) is optional. The refusal does not entail any consequence, except the impossibility of receive promotional material. Consent for such processing is expressed through the “flag“ of the appropriate mailbox at the bottom of this Privacy Policy with the words “I consent to the processing regarding the provision of my personal data for commercial and promotional purposes”. The User may withdraw his consent and therefore refuse to receive further promotional communications at any time by writing to [email protected].

The provision and/ or otherwise consent to the processing of data for profiling purposes of referred to in d) above is optional. Such refusal will not entail any consequences. Consent for such processing is expressed through the “flag“ of the appropriate mailbox in lime to this Privacy Policy bearing the words “I consent to the processing of my personal data for profiling purposes”. The User may revoke his consent and therefore refuse to provide his data for profiling purposes at any time by writing to [email protected].

The table below shows (i) how personal data are used; (ii) the type of personal data processed and (iii) the reasons and legal basis for the processing

F. HOW DO WE PROTECT YOUR DATA?

Data processing takes place mainly through automated tools and for the time strictly necessary to achieve the purposes for which they were collected. The appropriate security measures, as provided for by Regulation (EU) 2016/679 on the Protection of Personal Data, are observed to prevent data loss, illegal or incorrect uses and unauthorized access.
Please note that the processing of your personal data will be carried out by means of the following operations: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction of data.
The processing of the User’s personal data will be carried out both with the use of paper media and with the help of electronic, computer and telematic tools, in accordance with the methods and with appropriate tools to ensure the security and confidentiality of the data, in accordance with the provisions of art. 32 GDPR and the various provisions subsequently issued, so that at least the adequate level of data protection security required by law is guaranteed.

G. TO WHOM YOUR DATA IS DISCLOSED?

The data that the User will provide/ send for access to the FIDAVO portal and/ or otherwise to have the opportunity to use the investigation services offered therein will not be diffused in any way, but may be transmitted to the competent authorities for administrative or institutional purposes, as required by current legislation. More precisely, the data may be communicated to recipients belonging to the following categories:

• subjects who can access the data pursuant to the provisions of Law, Regulation or Community Legislation, within the limits provided by these Rules;
• subjects who need to access the data of the Users for purposes auxiliary to the relationship that exists with our company, to the extent strictly necessary to carry out auxiliary tasks (see, for example, the Credit Institutions);
• our consultants, to the extent necessary to carry out their duties on behalf of our Company, prior to the preparation of our letter of appointment to Responsible (Art. 28) that imposes the duty of confidentiality and security;
• other Data Processors appointed pursuant to Art. 28 of EU Regulation 679/2016 (list available from the Data Controller);
• to other companies that are part of the network of partners of FIDAVO LIMITED (list available from the Data Controller) for the same purposes indicated above;
• employees, performing administrative, accounting and commercial functions.

The communication of data will take place on Italian and European territory, if necessary. In addition, following special needs and in order to guarantee the User a better service, the data could be communicated, for the same purposes indicated above, also in non-European territory, pursuant to Articles. 44, 46 and 49 Paragraph 1 Lett. a) and c) of EU Regulation 679/2016.

In this regard, it is confirmed that:

• particular attention will be paid to compliance with the security measures provided by the Legislation for the processing of data that the owner becomes aware of in the context and for the purposes of execution of the existing contract;
• the data transferred on non-European territory will be managed directly by the Data Processors appointed by applying all the provisions of EU Regulation 679/2016, including standard contractual clauses, and the directives of the Data Controller under its direct control.

In any case, the User may always request, at any time, from the Data Controller, using the contact details indicated in this information, a copy of his personal data, information about the location where your personal data are processed and an updated list with the identification details of all data processors and processors and system administrators authorized to process your data.

H. HOW LONG DO WE KEEP YOUR DATA?

In compliance with the provisions of art. 5, paragraph 1, lett. e) of the GDPR, the User’s personal data are stored in a form that allows the identification of the data subject for a period of time not exceeding the achievement of the purposes for which the data are processed or according to the deadlines set by law. The check on the obsolescence of the data stored in relation to the purposes for which they were collected is carried out periodically. In particular, with regard to the retention period of your data, we observe that:

1. Where processing is necessary for the performance of a contract and/or the performance of pre-contractual measures, the data will be processed until the execution of this contract is completed and will be kept for the next 10 years, subject to the Data Controller’s legitimate interest in the event of legal cases/proceedings/court proceedings;
2. When processing is necessary to comply with a legal obligation to which the Data Controller is subject, the data will be retained until the law allows it;
3. When the processing is necessary for the pursuit of the legitimate interest of the Data Controller, the data will be retained until the law allows it;
4. When processing is carried out for the purposes of promotion and analysis of habits and consumer choices, and only if the User has provided a specific consent (optional), we will keep the collected data for the time strictly necessary for the management of the purposes mentioned above in accordance with the criteria based on compliance with current rules and fairness and balance between our legitimate interest and the rights and freedoms of the User. In the absence of specific rules providing for different retention times, and in the absence of a new explicit consent that the User must give in the near of the following deadline, we will use your data for marketing purposes for a maximum of 9 years and then delete it;
5. When processing is carried out for profiling purposes, and only if the User has provided a specific consent (optional), we will keep the collected data for the time strictly necessary for the management of the above mentioned purpose in accordance with the criteria based on compliance with current rules and fairness and balance between our legitimate interest and the rights and freedoms of the User. In the absence of specific rules that provide for different storage times, and in the absence of your explicit new consent that you will have to express to us near the next deadline, we will use this data for a maximum of 9 years and then delete it.

Personal data will in any case be kept for the fulfillment of obligations (e.g. tax and accounting) that remain even after the termination of the contract (cf. art. 2220 civil code); for these purposes, the Data Controller will keep only the data necessary for its prosecution and for the following 10 years, without prejudice to the Data Controller’s legitimate interest in legal proceedings/litigation.

I. LINKS TO OTHER WEBSITES

The FIDAVO portal may contain references or connections (“links“) to other websites not controlled by us and in respect of which these Privacy Policies are not applicable. We are therefore not responsible for the content or any processing of personal data carried out on such sites. We advise you to review the information of each site linked to this to identify the possible processing of personal data.

L. COOKIES

Cookies are small text files that the sites visited send to the User’s terminal, where they are stored, and then be transmitted to the same sites on the next visit. The FIDAVO portal uses its own technical cookies. These cookies, being of a technical nature, do not require the prior consent of the User to be installed and used. In particular, the cookies used by the FIDAVO portal can be traced back to the following subcategories:

• navigation or session cookies, that guarantee the normal navigation and use of the FIDAVO portal. Not being stored on the user’s computer, they vanish with the closing of the browser;
• analytical cookies, in which collect and analyze statistical information on the number of users and visits to the FIDAVO portal;
• social widgets and plugins: some widgets and plugins made available by social networks can use their own cookies to facilitate interaction with the reference site;
• profiling cookies, that are used to collect information on the preferences and habits expressed by the user during their browsing and thus make the advertisements provided by third parties more engaging and targeted

M. WHAT ARE YOUR RIGHTS?

Pursuant to EU Regulation 679/2016, the following rights are granted to the User:
the right to ask the Data Controller for access to personal data (Art. 15), rectification (Art. 16), the erasure of the same or the oblivion (Art. 17), the limitation of the processing of personal data (Art. 18), the right to data portability (Art. 20) or to object to their processing (Art. 21), in addition to the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effects which affect you or which have a significant effect on you (Art. 22).
Requests may be made towards:
FIDAVO LIMITED SRL, based in Dublin, 1 Watermill Lawn, Dublin 5, D05 K738 email: [email protected].
The User is also granted the right to lodge a complaint with the competent supervisory authority (art. 77 of the Regulation) if you believe that the processing carried out by the Data Controller is not compliant.

N. CHANGES TO THE PRIVACY POLICY

These Privacy Policies may be periodically updated or amended without notice. Any changes to the following policy will affect the processing of the data collected following the change. We therefore ask you to periodically review any changes to Privacy.

This privacy policy and data processing is updated in November 2021.