ADTONES Privacy Policy

This privacy policy (hereinafter, “Privacy Policy“) refers to www.adtones.com, including dedicated and reserved areas for registered users (hereinafter, the “Site“) and describes the activities and means of personal data processing fulfilled by Adtones Ltd. (hereinafter, “ADTONES“), through the Site, which is owned by Adtones Ltd. and registered by the Company itself.

ADTONES recognizes the importance of its users’ privacy and commits itself to respecting it. ADTONES processes user’s personal information (“Personal Data“) when the user visits the Site and uses the services and functionality on it. The Privacy Policy has been drafted in accordance with Recommendation no. 2/2001, adopted on 17 May 2001 by the Data Protection Working Party – Art. 29, related to the minimum requirements for the online data collection in the European Union and also represents information to interested parties in compliance with Art. 13 of General Data Protection Regulation (“GDPR“) and the local applicable law (together, “Privacy Law“). The Privacy Policy specifies who the Data Controller is, who controls and manages the Personal Data collected and processed through the Site, what personal information is collected, for what purposes and by which means the Personal Data are processed, the scope of communication to third parties and the possible transfer abroad, the security measures adopted to protect and defend such data and the means by which the user can verify the processing of data concerning him/her and exercise the rights recognized by the Privacy Law.

However, this information is only made for the Site and for the activities and services provided by ADTONES also through its own Data Processors and not for any other websites that may be consulted by the user through links and/or activities carried out by third parties.
In case of other websites’ consultation, please refer to the respective Privacy Policy.

1. TYPES OF DATA COLLECTED

1.1 Navigation data
Visiting and consulting the Site does not generally involve collection and processing of user’s Personal Data. The Personal Data processing of users who visit and consult the Site is limited to the so-called navigation data which transmission is necessary for the functioning of computer systems and of programs essentials for the operation of the Site but which, by their very nature and in conjunction with other data, may permit the identification of users. This category includes, for example, the IP addresses (Internet Protocol) or the domain names of the computer used to visit the Site, as well as other parameters concerning the operating system used by the user to connect to the Site. The collection of Navigation data occurs automatically and inevitably and can only be used to obtain statistical information on the use of the Site and to verify its proper functioning. If expressly requested, such data may be used by the Public Authority to ascertain liability in the event of computer offenses committed against the Site and/or third parties, in accordance with the procedures in force at the competent Authorities. Except for this possibility, navigation data described above are only temporarily kept in compliance with the applicable regulations.

1.2 Data voluntarily provided by individual users
In addition, ADTONES collects and processes Personal Data voluntarily provided by individual users that consist of those data collected through the sending of e-mail, the interaction with the Site’s features, the request for services offered by the Site, the sending of their own Curriculum Vitae, the compilation of other specific format for access to reserved sections of the Site.

Personal Data that ADTONES collects and processes include name, gender, place and date of birth, nationality, contact information such as addresses, phone numbers, e-mails and other information necessary for the purpose of conducting the Owner business. Adtones will not collect, hold, use or disclose sensitive information (such as information about racial or ethnic origins, political or religious beliefs, gender, date of birth or health information) except with your consent or where required or permitted by law.
Users are responsible for any third-party Personal Data obtained, published or shared through the Website and confirm that they have the third party’s consent to provide the Data to the Owner.

2. MEANS AND PURPOSES FOR PROCESSING PERSONAL DATA
The Data will be processed both manually and with the help of electronic instruments to respond and manage requests for information and/or materials of the user, questions, communications or feedback from users; to provide services rendered on the Website, including registration and updates through price sensitive press releases, presentation, interim reports, annual reports, and to manage the initiatives organized through the Site; to carry out recruitment and staff selection activities; for the management of sales activities and sales and after-sales services, such as administrative and accounting activities, return and guarantee management, fraud prevention, customer relationship management, including compliance with legal obligations, regulations and Community legislation (including anti-money laundering legislation) and for the rights’ enforcement through legal action.

3. METHODS OF PROCESSING
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
These include: protection of passwords using industry standard encryption, measures to preserve system security and prevent unauthorised access, and back-up systems to prevent accidental or malicious loss of data. Paper copies are stored in locked cabinets or restricted access archive rooms. Documents verifying your identity will be stored in a secure electronic environment.

4. PLACE
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own.

5. RETENTION TIME
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and, in any case, not longer than the one provided for by the applicable regulations.
Therefore:
• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

6. NATURE OF PERSONAL DATA GRANTING
The Personal Data granting for the purposes mentioned in point 2 above, is necessary to allow ADTONES to respond to requests for information, to provide the services requested through the Site, including registration, to manage sales activities and after-sales services; in the event of non-submission of Personal Data for the purposes referred to in point 2, ADTONES will not be able to answer to requests for information, to provide the services requested through the Site, to manage sales activities and after-sales services.

7. LEGAL BASIS OF PROCESSING
The Owner may process Personal Data relating to Users if one of the following applies:
• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

8. PERSONAL DATA DISCLOSURE
Personal Data are accessible to the Data Processor indicated below, to the other persons who will act as external Controllers appointed by ADTONES and, in their quality as Persons in charge of the Processing, to the staff of ADTONES involved in the provision of services and features from time to time offered by ADTONES according to criteria of need.

Personal Data may be disclosed to agencies, authorities, public institutions and legitimate recipients in compliance with laws and regulations; they may be made accessible to self-employed professionals and collaborators, also organized in associated form, third parties suppliers of professional and technical service for processing purposes referred to in paragraph 2 that assist ADTONES in legal, tax, social security, accounting and/or organization’s field, who will act as Data Processors or Persons in charge of the Processing, as the case may be, without prejudice to the adoption of Personal Data security and protection measures pursuant to current legislation.

Personal Data may also be disclosed to third parties in the event of extraordinary transactions (e.g. mergers, acquisitions, transfer of business, etc.) by ADTONES. Only the information necessary to perform their respective functions will be provided to such those persons. Such third parties will commit to use the information received only for purposes for processing specified above, to keep them confidential and secure and to comply with the protection of Personal Data required by law and any instructions given by ADTONES.

Personal Data may also be transferred abroad to persons established in countries that are not members of the European Union that could not guarantee an adequate level of protection pursuant to the Privacy Law. In such cases, ADTONES transfers Personal Data to such third countries after the adoption of the measures laid down in Art. 44 and subsequent of the GDPR in order to legitimate the transfer and ensure adequate protection to transferred Personal Data. Persons who receive user’s Personal Data may process them as Controllers, Processors and/or Persons in charge of the Processing, as the case may be.

The complete and updated list of Data Processors will be provided on request by contacting ADTONES at privacy@adtones.com.
Personal Data will in no case be subject to dissemination.

9. AUTOMATIC DATA COLLECTION MECHANISMS – COOKIES
The Site uses Cookies and other technologies to read and/or store information on the user’s device. In order to provide a detailed description of these technologies, please refer to the Cookie Policy [http://www.adtones.com/cookie-policy], here fully referenced.

10. USER’S RIGHT
User may exercise at any time the rights to which he/she is entitled to pursuant to Articles 15 – 22 of the GDPR including, for example, the right to obtain confirmation of the existence or not of Personal Data relating to him/her, verifying its content, source and accuracy, requesting its integration, updating, rectification, deletion, transformation into an anonymous form, portability. The user may object in whole or in part, or ask for the restriction of the processing of data for legitimate reasons.
In particular, Users have the right to do the following:
• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.
How to exercise these rights
For any question or request about the processing of Personal Data and for exercise the rights granted by the GDPR, the user may contact ADTONES at the following address: [privacy@adtones.com].

11. AMENDMENTS AND UPDATES OF PRIVACY POLICY
The Privacy Policy is subject to amendments and updates and the version currently in force is that published on the Site. Amendments of the Privacy Policy are communicated through publication on the Site. Please periodically check the Privacy Policy to be informed of any changes.Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

12. DATA CONTROLLER
The Data Controller is ADTONES Ltd., a company registered under UK Law Company No. 9515191 based in 35A South Street London W1K 2XF United Kingdom

13. CONTACT DETAILS OF THE DATA PROTECTION OFFICER
Adtones has appointed a Data Protection Officer, who can be contacted at the email address dpo@adtones.com