- DATA CONTROLLER
- Preliminary information
The Data controller is Mailberry a project of Digity Solutions SH.P.K
Data controller email address: firstname.lastname@example.org
- Who is Mailberry
Mailberry is a Database that, through other websites owned by the same, it deals with the collection and management of user data for the services offered. Mailberry is owned by Digity Solutions Sh.p.k. registered in Rr. Barrikadave 11, 1016 Tirana, Albania (VAT M02110031G) represented by Luciano Zefi.
- TYPES OF DATA COLLECTED
Among the Personal Data collected by this Application, independently or through third parties, there are name, surname, company name, title, tax code, address, email, city, telephone number, postal code, IP address, date of the optin, country of optin, cookies and usage data.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he has the right to communicate or disseminate them, relieving the Data controller from any liability to third parties.
- METHODS AND PLACE OF THE PROCESSING OF THE DATA COLLECTED
3.1 Processing methods
The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. The treatment is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, may have access to the Data, hosting provider, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Owner. The updated list of Managers can always be requested from the Data Controller.
It should be noted, in fact, how the personal information of Users, although managed directly by Mailberry, is collected by the SendPulse platform owned by third parties.
3.2 Legal basis of the processing
The Data Controller processes Personal Data relating to the User if one of the following conditions exists:
- the User has given consent for one or more specific purposes; Note: in some systems, the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
- processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
- processing is necessary to fulfil a legal obligation to which the Data Controller is subject;
- processing is necessary for the execution of a public interest task or for the exercise of public powers with which the Data Controller is invested;
- the processing is necessary for the pursuit of the legitimate interest of the owner or third parties.
However, it is always possible to request the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for in a contract or necessary to conclude a contract.
The Data are processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, contact the owner. The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of treatment, the User can refer to the section relating to the details on the processing of Personal Data.
The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data. If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Data Controller by contacting him at the details shown at the beginning.
3.4 Retention period
The data are processed and stored for the time required by the purposes for which they were collected.
- Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
- Personal Data collected for purposes attributable to the legitimate interest of the Owner will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
When the treatment is based on the User’s consent, the Data Controller can keep Personal Data longer until such consent is revoked. In addition, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority. At the end of the retention period, Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
- PURPOSE OF THE PROCESSING OF THE COLLECTED DATA
User data are collected to allow the Owner to provide its services, as well as for the following purposes: contacting the user, managing contacts and sending messages, billing communications, tracking platform, registration and authentication, statistics and Display of content from external platforms.
To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant for each purpose, the User can refer to the relevant sections of this document.
Details on the processing of personal data
Personal data are collected for the following purposes and using the following services:
4.1 Contact the User
By filling in the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other kind indicated by the form header.
Personal Data collected: surname, email, name.
4.2 Contact management, sending messages and push notifications
This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User.
These services could also allow you to collect data relating to the date and time of display of the messages by the User, as well as the interaction of the User with them, such as information on clicks on the links inserted in the messages. In particular, this type of service for contacting users uses various channels, which will be specifically described below.
Through the mailing service, the Application contacts the User using the SendGrid.com platform, i.e. an address management service and sending email messages.
The personal data collected concern only the User’s email.
4.2.2. Push notifications
Push notification is a type of instant messaging with which the message reaches the recipient without this having to perform a download operation (pull mode). This mode is typically used by applications such as WhatsApp, or services of operating systems such as Android, or as numerous applications derived from websites. To allow push notifications to reach the recipient, it is essential that the application is active, i.e. it operates in the background and is online. Subsequently, the user must have authorized the application to send the notifications. Clearly, if the account is disconnected from the network or the application ended, push notification cannot come; in these cases, the user receives push messages as soon as he reconnects the account (login) or restarts the application.
The Application uses the onesignal.com platform to send push notifications to users who have explicitly accepted this service.
Personal data collected: browser ID
4.2.3 Sms and Messages
The Application uses messaging channels to contact the User where he has explicitly accepted this service. Specifically, the platforms used for the messaging service are: messenger.com and viber.com
Personal data collected: browser ID, name, surname.
4.3 Tracking platform
This type of service has the function of hosting Data and files that allow this Application to function, allow its distribution and provide a ready-to-use infrastructure to provide the specific functionality of this Application. Some of these services work through servers located geographically in different places, making it difficult to determine the exact place where Personal Data is stored.
TUNE: is the tracking platform that uses this application to allow customers and affiliates to keep track of the commissions generated.
Personal Data collected: name, surname, company name, title, tax code, address, email, city, postal code, IP address, date of the optin, country of the optin.
4.4 Registration and authentication
By registering or authenticating, the User allows the Application to identify him and give him access to dedicated services. Depending on what is indicated below, registration and authentication services could be provided with the help of third parties. If this happens, this application will be able to access some data stored by the third-party service used for registration or identification. Registration takes place directly through our tracking platform.
TUNE: is the tracking platform that uses this application to allow customers and affiliates to keep track of the commissions generated
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behaviour. Among the services used by the application, there is Google Analytics (Google Inc.), Google Analytics is a web analysis service provided by Google Inc. (“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 could use Personal Data to contextualize and personalize the advertisements of its own advertising network.
Personal Data collected: Cookies and Usage Data
4.6 Viewing content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. In the event that a service of this type is installed, it is possible that, even if the Users do not use the service, the same collects traffic data relating to the pages in which it is installed.
Google Fonts (Google Inc.) Google Fonts is a font style visualization service managed by Google Inc. that allows this Application to integrate such content within its pages.
Google Maps Widget (Google Inc.) Google Maps is a map visualization service managed by Google Inc. that allows this Application to integrate such content within its pages.
Personal Data collected: Cookies and Usage Data.
YouTube Video Widget (Google Inc.) YouTube is a video content viewing service managed by Google Inc. that allows this Application to integrate such content within its pages.
Personal Data collected: Cookies and Usage Data.
- ADDITIONAL INFORMATION ON PERSONAL DATA
5.1 The Service is not aimed at children under 13 years old
Users declare that they are of legal age according to the legislation applicable to them.
Minors can use this application only with the assistance of a parent or guardian. In no case under the age of 13 can use this application.
- USER RIGHTS
Users can exercise certain rights with reference to the data processed by the owner.
In particular, the User has the right to:
- withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.
- object to the processing of their data. The user can object to the processing of their data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
- access their data. The user has the right to obtain information on the data processed by the owner, on certain aspects of the processing and to receive a copy of the data processed.
- verify and request a correction. The User can verify the correctness of his Data and request its updating or correction.
- obtain the limitation of the treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose other than their conservation.
- obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
- receive your data or have it transferred to another holder. The User has the right to receive their Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its transfer without obstacles to another owner. This provision is applicable when the Data is processed with automated tools and the treatment is based on the User’s consent, on a contract of which the User is a party or on contractual measures connected to it.
- propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.
6.1 Details on the right to object
When Personal Data are processed in the public interest, in the exercise of public powers with which the Data Controller is invested or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons related to their particular situation.
Users are reminded that, if their data were processed for direct marketing purposes, they can oppose the processing without giving any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.
6.2 How to exercise your rights
To exercise the rights of the User, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within a month.
- FURTHER INFORMATION ON TREATMENT
8.1 Defence in court
The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its possible establishment for the defence against abuse in the use of this Application or related Services by the User. The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of the public authorities.
8.2 Specific information
8.3 System log and maintenance
For needs related to operation and maintenance, this Application and any third party services it uses may collect system logs, i.e. files that record the interactions and which may also contain Personal Data, such as the User IP address.
8.4 Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time to the Data Controller using the contact details.
8.5 Reply to “Do Not Track” requests
This Application does not support “Do Not Track” requests. To find out if any third-party services used support them, the User is invited to consult their respective privacy policies.
- DEFINITIONS AND LEGAL REFERENCES
- Personal Data (or Data)
It constitutes personal data any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.
- Usage data
These are the information collected automatically through this Application (also from third party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (successful, error, etc.). country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.
The individual who uses this Application, unless otherwise specified, coincides with the interested party.
The natural person to whom the Personal Data refers.
- Data Processor (or Responsible)
- Data Controller (or Owner)
The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
- This project
The hardware or software tool through which Users’ Personal Data is collected and processed.
The service provided by this application is defined in the relative terms (if any) on this site/application.
- European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.
A small portion of data stored within the User’s device.
- Legal references
This privacy statement is drawn up on the basis of multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.
The processing of personal data is entrusted to Mailberry, which is owned by Digity Solutions Sh. P.K, a company registered in Albania, fully complies with the aforementioned European legislation, although it is not required to do so.
Unless otherwise specified, this privacy statement only concerns this project.