Privacy Policy

Privacy Policy

This Privacy Policy is provided pursuant to section 13 of Legislative Decree. N. 196/2003 – Personal Data Protection Code.

The data controller is ROIALTY s.r.l., a limited liability company with its main headquarters registered in Milan (Italy), via Privata Stefanardo da Vimercate n.28 – 20128, Fiscal Code and VAT no. 08891260963.

The data controller hereby intends to describe its process for analyzing personal data and in particular:

    1. The type of data processed and whether it’s mandatory or optional to confer them.
    2. The purposes and methods of personal data processing, concerning data either collected via the site or automatically collected and processed to provide a service;
    3. The consequences of a refusal to provide personal data;
    4. Categories of individuals or entities to whom personal data may be disclosed, in their capacity as data processors or data controllers, and information on personal data disclosure to third parties;
    5. The users’ rights pursuant to article 7 of Legislative Decree 196/2003.

 

  1. I) PURPOSES AND PROCESSING ARRANGEMENTS

The data controller hereby informs that the data provided by the users will be processed for the following purposes:

  1. Performing a contract or process and respond to specific queries received through the contact forms available on this website;
  2. Sending periodic newsletters with information and updates pertaining to ROIALTY services, including any promotions, activities and initiatives promoted by the data controller.

Personal data will be processed using automated tools only for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are taken to prevent loss, illicit or incorrect and unauthorized access to data. The Data Controller may transfer the personal data in Italy and abroad, within the European Union, in accordance with article 42 of Legislative Decree no. 196/2003 and outside the EU in compliance with article 43 of Legislative Decree no. 196/2003.

 

 

  1. II) DISCLOSURE OF DATA TO THIRD PARTIES

ROIALTY may disclose personal data to third parties involved in the operation of the website (such as administrative and commercial personnel) or external parties (such as technical service providers, service providers for the delivery of communication services, mail carriers, hosting providers, IT companies, agencies) appointed, if necessary, as data processors. The complete and updated list of data processors can be requested at any time to the data Controller.

 

III) TYPE OF DATA COLLECTED

  • Data disclosed by users

Personal data voluntarily provided by users through the website contact forms and online tools and applications may include name, surname, email,and telephone number. Mandatory data will be identified and marked with an asterisk *. Disclosure of personal data is mandatory for the purposes referred to in letter a) of section I “PURPOSES AND PROCESSING ARRANGEMENTS” (i.e. performing the services including the use of online tools and applications, interact with the data controller, inquiring about the services and allow ROIALTY to respond to queries). Failure to disclose personal data for the above purpose will prevent users from receiving the services, being contacted by the data controller and from obtaining the information requested. Users are free to disclose personal data for the purpose of receiving newsletters as per letter b) of section I “PURPOSES AND PROCESSING ARRANGEMENTS”, and may withdraw their consent at any time by providing notice to the data controller in accordance with paragraph “RIGHTS OF” or by clicking the “unsubscribe” link on every newsletter. A refusal to confer personal data for such purpose will result in the impossibility to receive the newsletter from ROIALTY.

  • Data automatically collected

When accessing the website, the data controller may automatically collect some data, such as IP address, country of origin, browser and operating system, time spent on each page, the page response times, download errors, information on the interaction with the page. The data thus collected although is not used to identify individuals, it may, due to its characteristics, help identify those users by associating the data with other information. The above data will be stored temporarily in compliance with applicable law. ROIALTY, as part of its business activities, may acquire, through an indexing process and in compliance with the access criteria set up by the monitored sites, a range of content publicly available on social media, generally accessible to anyone. The data collected, although made publicly available by users, will not be disclosed to third parties nor it will be used for direct or indirect marketing purposes, or to profile users without their explicit consent. It is excluded any access to internet pages protected by authentication credentials, email addresses or information that users have been unwilling to share or make accessible to anyone in public mode.

If users log in to Social DNA tool available on our website, then Controller also collect certain information that is necessary to provide user with feedback. The content of this is determined by what users choose to share, but may include:

    • Facebook userID, as specific to the Social DNA application (note: this is different from tha Facebook platform ID);
    • LikeIDs of the Pages you like or follow on Facebook;
    • User Facebook status updates and other user-generated text data;
    • User Facebook email address;
    • Any profile information that a User has chosen to make public;

By using social DNA users will login with Facebook and submit their Facebook Likes and view the output of the API (Application Programming Interface). Users are asked to log in so ROIALTY can collect their LikeIDs. ROIALTY will not post to a user’s wall, store Users’ Facebook profile information or any results of the output. Any personal information a user submits to us in order to sign up to or use Social DNA is strictly confidential and shall not be revealed by Controller to any third party. Controller shall never pass users’ personal details to an external third party for marketing purposes without their explicit consent.

If someone, in using the Social DNA service sends Facebook LikeIDs to the application on behalf of a third party, he must also warrant he has obtained the permission of the individual concerned.

 

  1. IV) CHANGES TO THE PRIVACY POLICY

ROIALTY reserves the right to modify this privacy policy at any time reflecting any such changes in the privacy section of the website. Users are invited to visit constantly the privacy policy section, referring to the last modified date indicated at the bottom of the Privacy Policy. If users do not wish to agree to any changes to this Privacy Policy, then they must stop accessing the website and can request the data Controller to delete their personal data.

 

  1. IV) USERS RIGHTS

Users are entitled to exercise their rights according to article 7 of the Personal Data Protection Code, hereto included for convenience of reference only. Any request shall be addressed to the data Controller by sending an e-mail to [email protected] or a registered mail by post to:

ROIALTY s.r.l.
Via privata Stefanardo da Vimercate 28, 20128 Milano, Italia

 

Privacy Policy

This Privacy Policy is provided pursuant to section 13 of Legislative Decree. N. 196/2003 – Personal Data Protection Code.

The data controller is ROIALTY s.r.l., a limited liability company with its main headquarters registered in Milan (Italy), via Privata Stefanardo da Vimercate n.28 – 20128, Fiscal Code and VAT no. 08891260963.

The data controller hereby intends to describe its process for analyzing personal data and in particular:

    1. The type of data processed and whether it’s mandatory or optional to confer them.
    2. The purposes and methods of personal data processing, concerning data either collected via the site or automatically collected and processed to provide a service;
    3. The consequences of a refusal to provide personal data;
    4. Categories of individuals or entities to whom personal data may be disclosed, in their capacity as data processors or data controllers, and information on personal data disclosure to third parties;
    5. The users’ rights pursuant to article 7 of Legislative Decree 196/2003.

 

  1. I) PURPOSES AND PROCESSING ARRANGEMENTS

The data controller hereby informs that the data provided by the users will be processed for the following purposes:

  1. Performing a contract or process and respond to specific queries received through the contact forms available on this website;
  2. Sending periodic newsletters with information and updates pertaining to ROIALTY services, including any promotions, activities and initiatives promoted by the data controller.

Personal data will be processed using automated tools only for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are taken to prevent loss, illicit or incorrect and unauthorized access to data. The Data Controller may transfer the personal data in Italy and abroad, within the European Union, in accordance with article 42 of Legislative Decree no. 196/2003 and outside the EU in compliance with article 43 of Legislative Decree no. 196/2003.

 

 

  1. II) DISCLOSURE OF DATA TO THIRD PARTIES

ROIALTY may disclose personal data to third parties involved in the operation of the website (such as administrative and commercial personnel) or external parties (such as technical service providers, service providers for the delivery of communication services, mail carriers, hosting providers, IT companies, agencies) appointed, if necessary, as data processors. The complete and updated list of data processors can be requested at any time to the data Controller.

 

III) TYPE OF DATA COLLECTED

Personal data voluntarily provided by users through the website contact forms and online tools and applications may include name, surname, email,and telephone number. Mandatory data will be identified and marked with an asterisk *. Disclosure of personal data is mandatory for the purposes referred to in letter a) of section I “PURPOSES AND PROCESSING ARRANGEMENTS” (i.e. performing the services including the use of online tools and applications, interact with the data controller, inquiring about the services and allow ROIALTY to respond to queries). Failure to disclose personal data for the above purpose will prevent users from receiving the services, being contacted by the data controller and from obtaining the information requested. Users are free to disclose personal data for the purpose of receiving newsletters as per letter b) of section I “PURPOSES AND PROCESSING ARRANGEMENTS”, and may withdraw their consent at any time by providing notice to the data controller in accordance with paragraph “RIGHTS OF” or by clicking the “unsubscribe” link on every newsletter. A refusal to confer personal data for such purpose will result in the impossibility to receive the newsletter from ROIALTY.

When accessing the website, the data controller may automatically collect some data, such as IP address, country of origin, browser and operating system, time spent on each page, the page response times, download errors, information on the interaction with the page. The data thus collected although is not used to identify individuals, it may, due to its characteristics, help identify those users by associating the data with other information. The above data will be stored temporarily in compliance with applicable law. ROIALTY, as part of its business activities, may acquire, through an indexing process and in compliance with the access criteria set up by the monitored sites, a range of content publicly available on social media, generally accessible to anyone. The data collected, although made publicly available by users, will not be disclosed to third parties nor it will be used for direct or indirect marketing purposes, or to profile users without their explicit consent. It is excluded any access to internet pages protected by authentication credentials, email addresses or information that users have been unwilling to share or make accessible to anyone in public mode.

If users log in to Social DNA tool available on our website, then Controller also collect certain information that is necessary to provide user with feedback. The content of this is determined by what users choose to share, but may include:

By using social DNA users will login with Facebook and submit their Facebook Likes and view the output of the API (Application Programming Interface). Users are asked to log in so ROIALTY can collect their LikeIDs. ROIALTY will not post to a user’s wall, store Users’ Facebook profile information or any results of the output. Any personal information a user submits to us in order to sign up to or use Social DNA is strictly confidential and shall not be revealed by Controller to any third party. Controller shall never pass users’ personal details to an external third party for marketing purposes without their explicit consent.

If someone, in using the Social DNA service sends Facebook LikeIDs to the application on behalf of a third party, he must also warrant he has obtained the permission of the individual concerned.

 

  1. IV) CHANGES TO THE PRIVACY POLICY

ROIALTY reserves the right to modify this privacy policy at any time reflecting any such changes in the privacy section of the website. Users are invited to visit constantly the privacy policy section, referring to the last modified date indicated at the bottom of the Privacy Policy. If users do not wish to agree to any changes to this Privacy Policy, then they must stop accessing the website and can request the data Controller to delete their personal data.

 

  1. IV) USERS RIGHTS

Users are entitled to exercise their rights according to article 7 of the Personal Data Protection Code, hereto included for convenience of reference only. Any request shall be addressed to the data Controller by sending an e-mail to [email protected] or a registered mail by post to:

ROIALTY s.r.l.
Via privata Stefanardo da Vimercate 28, 20128 Milano, Italia