PRIVACY POLICY FOR THE PROCESSING OF USERS DATA

Dear Sir/Madam,

we wish to inform you that Legislative Decree no. 196 of 30/06/2003 (“Users Data Protection Code”) and EU Regulation no. 679/2016 (henceforth GDPR) provide for the protection of persons and other subjects with regard to the processing of personal data.

In accordance with the aforementioned regulations, such processing will be based on the principles of fairness, lawfulness, purpose limitation and storage, minimisation, accuracy, integrity and transparency and the protection of your confidentiality and your rights, as well as the principle of accountability set out in Article 5 of the GDPR. The same will be processed in accordance with the legal provisions of the GDPR and confidentiality obligations as well as those of the Privacy Code in force.

According to Art. 13 of Legislative Decree no. 193/2003 and the GDPR we therefore provide you with the following information:

By giving consent, who are you authorising to process your data? – (Data controller)

The data controller is Bee-Part S.r.l. – with registered office in Via Edoardo Ressi n. 17 – Milan – P.I. 13453900964 – bee-part@lamiapec.it, in the person of the Sole Administrator and Legal Representative Fabio Puglisi

The Data Processor is Federico Mana

The Privacy Officer is Giancarlo d’Adamo, lawyer at the Court of Turin.

To exercise your rights or for any other request, please write a: privacy@bee-part.net

giancarlo.dadamo@gmail.com

What data we collect and process (Types of data)

The Personal Data collected by the BeePart Platform includes, but is not limited to: first name; last name; telephone number; state; country; postal code; gender; date of birth; city; physical address; email address; tax code; billing address; shipping address; payment information; device information; username; User ID; password, etc. The Personal Data is freely provided by the User. You may freely refuse to disclose it, however BeePart informs you that in the event of a refusal, it may be impossible for BeePart to give you access to the services of the Platform such as forums and services. In cases where BeePart indicates certain Data as optional, however, you are free to refrain from providing this Data, without this having any effect on your participation in the activities or services.

Processing of particular categories of data

We would also like to inform you that for the purposes of the aforementioned processing, in addition to the data identifying your person (personal data), the Data Controller may become aware of data defined as ‘Particular’ in accordance with Art. 9 of the GDPR (special categories of data), such as those that can detect racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as process genetic data, biometric data intended to uniquely identify a natural person, data relating to health or sex life or sexual orientation of the person. In this regard, we inform you that in order to be able to process the particular categories of data you will be asked to provide us with your specific and express consent. Specific security measures are observed to prevent the loss of data, unlawful or incorrect use and unauthorised access.

Any use of Cookies – or other tracking tools – by the Data Controller is for the purpose of providing the Service requested by the User, in addition to the further purposes described in the Cookie Policy document.

The Data Controller informs the User that Hivebrite, as well as its subcontractors, uses a tracking technology on its terminal such as cookies whenever the User navigates on the Platform subject to the conditions described in the Data Controller Cookie Policy. 

In particular, Hivebrite may use a cookie called “Amplitude”, to enable analytics of the User’s journey on the platform. This cookie involves a transfer of personal data to the United States of America. Hivebrite has signed Standard contractual clauses in order to comply with the requirements of the GDPR on personal data transfer, and will not use this cookie without gathering your consent first.

For more information about the processing carried out by Hivebrite as data controller, the User is invited to consult Hivebrite’s privacy policy.

Why and what do we need your data for? – (Purpose of the processing for which the data are intended)

Your personal data will be processed exclusively for the following purposes: 

Account creation: 

With this registration, BeePart registers you on the Platform. Technically, your data is entered into a database and your personal profile is created and not accessible to other members. Once the account has been created, you can interact, participate in discussions and use the services. As already specified, the other subscribers to the Platform will see your name and surname (and so will you of the other subscribers), and this will allow you to identify yourself without the risk of Fake profiles and avoid the ‘Catfish’ phenomenon.

Mailing list or newsletter: 

by registering to the mailing list or newsletter, the User’s email address is automatically included in a list of contacts to whom email messages containing information, including of a commercial and promotional nature, relating to the Platform’s activities may be sent. User contact: Your data will be used to contact and interact with you.

Management of User databases:

this type of processing allows the Controller to track the User’s activities through statistical functions. These activities are aimed at investigations to improve the services rendered by the Platform.

Platform services, hosting, payments, etc.: 

these services are of a technical nature and serve to make possible the provision of the various services provided by the platform. In this sense, it may be necessary to use your data. We are thinking for example of: analytical tools, for managing user registration, for managing comments and the database, for subscribing to Partner services (courses, workshops), for processing payments, etc. As can be easily understood, the use of such tools involves the collection and processing of Personal Data. Some of these services operate through specialised platforms and servers located geographically in different places, making it difficult to determine the exact place where Personal Data is stored.

Statistical use:

The services contained in this section allow the Data Controller to monitor and analyse traffic data and serve to keep track of the User’s behaviour. We give you some information on the Google Analytics 4 service (Google Ireland Limited).Google Analytics is a statistics service provided by Google Ireland Limited (‘Google’). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualise and personalise the ads in its advertising network. In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data centre or server. To learn more, you can consult Google’s official documentation. For an understanding of Google’s use of data, please refer to Google’s partner policy. Personal data processed: Usage Data; Number of Users; Session Statistics; Tracking Tools.

Registration (contract) and invoicing, legal uses:

By subscribing you enter into an agreement with BeePart. In this case your data will be processed in order to fulfil contractual, pre-contractual obligations arising from your existing relationship with BeePart By subscribing to certain forms/modes of participation in the Platform, which are not free of charge, your data will be used to fulfil tax obligations. In addition, your data may be processed to fulfil obligations provided for by laws or Community regulations, or to comply with requests from the Authority;

What do we do with your data?  ( Treatment modalities)

The processing methods and criteria will be those naturally connected and necessary to the pursuit of the aforementioned purposes. Processing is carried out by means of the operations or set of operations represented by the collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and distribution of personal data.

In addition to manual processing, the processing will be carried out with the aid of information systems (possibly also on paper) through which personal data will be processed and stored. The processing may also be carried out in collaboration with external managers or authorised external parties such as, but not limited to: accountants, doctors, or parties authorised by law. The collection of your data is in part obligatory, suffice it to say that without your consent to the processing, it is not possible to proceed with registration on the Platform. Any failure to provide personal data, or the provision of incorrect personal data, or failure to consent to its processing, will make it impossible to continue the activities. For uses other than those indicated, however, such as commercial communications or information in general on the centre’s activities, you may opt not to consent to the processing of your data, but you may still obtain the communications.  

How long do we keep them? (data retention)

The personal data processed shall be retained for the time strictly necessary to achieve the aforementioned purposes and for the entire duration of the registration; furthermore, since the data will be included in contracts and tax documents, they shall be retained by the Owner for the period of time envisaged and as compulsory by law and at the same time to protect Bee Part’s interests and right of defence, having regard to the limitation periods laid down by the applicable legislation. To this end, we inform you that the statute of limitations of a contractual nature is 10 years, and of equal duration is the obligation to keep accounting records.

To whom do we communicate them? (Scope of communication and distribution of data)

The data may be disclosed to other partners of BeePart, in any case always for the fulfilment of the above-mentioned purposes: in this case, the identification data of the corresponding data controller and of the possible data processors may be acquired from the public register kept by the Guarantor for the protection of personal data and from the above-mentioned subjects. Personal data may be disclosed to Public Administrations and/or Private Entities, as well as to third parties for the supply and management of IT and filing systems. They are also communicated to subjects who are linked to the Data Controller by a collaboration relationship. For example, Partners who provide services on the Platform. A specific agreement has been concluded between these parties and the Controller to protect the use of your data. Other parties linked by a professional relationship (e.g. an accountant) have been contracted to define the form and limits of the use of your data. They therefore act under the directives of the Data Controller.  Personal data are not subject to dissemination unless required by law or regulation.

Do we transfer them to other countries? (Data Transfer of personal information)

Your data may be transferred to subjects resident/established abroad. This is also due to the international nature of the Platform’s activity, which is intended to connect the freediving community without territorial limits. The personal data you provide us with are stored on servers located within the European Union. It is in any case understood that the Owner, should it become necessary, will have the right to move the servers also outside the European Economic Area. In this case, the data controller hereby ensures that such transfer will take place in accordance with the applicable legislation based on an adequacy decision or Standard Contractual Clauses approved by the European Commission.

What rights can you exercise? (Exercise of the users’ rights)

You may assert your rights under Articles 15 et seq. of the GDPR by contacting the Data Controller or the Data Processor. In particular, you have the right to obtain confirmation from the Data Controller as to whether or not personal data concerning you exist and to have them made available in an intelligible form. In addition, he/she has the right to be informed of the origin of the data, the purposes and methods of processing, the logic applied to the processing, the identification details of the Data Controller and the persons from whom the data may be known; he/she also has the right to obtain the updating, rectification and integration of the data, the cancellation, transformation into anonymous form or blocking of data processed in violation of the law; he/she has the right to oppose, for legitimate reasons, the processing of the data. Where applicable, you also have the right under Articles 16-22 of the GDPR (right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object, right to object to automated processing, including profiling). In any case, you always have the right to lodge a complaint with the competent supervisory authority (Garante per la protezione dei dati personali), pursuant to Art. 77 of the GDPR, if you consider that the processing of your data is contrary to the legislation in force. We also inform you that the processing is not based on Art.6 We also inform you that the processing is not based on Art. 6 para. 1 lit. a) or Art. 9 para. 2 lit. a), for which reason the processing is carried out by requesting your consent, which can also be revoked at any time. There are no automated decision-making processes and no profiling activities are carried out.

For help and assistance: info@bee-part.net

Bee Part s.r.l. Via Adeodato Ressi 17 – 20125 Milano – IT P.IVA: IT13453900964 - C.F.: 134539009642024 © Bee-part Srl, All rights reserved.