Who we are
The protection of your Privacy is one of our main objectives.
Please note that on the various pages of the ATENEYA website where personal data are collected in order to provide the services we provide, specific information will be published in accordance with the provisions of Article 13 of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF COUNCIL of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC – General Data Protection Regulation (hereinafter, “ Regulation ”) for your analysis before providing the personal data requested and collected by us, as mentioned above.
The information and personal data by you or that we have access to in the scope of the provision of the various services and products by ATENEYA, will be treated in accordance with the provisions of the Regulation and with the confidentiality obligations to which all ATENEYA employees are contractually and legally bound.
In accordance with the provisions of the Regulation, the processing of personal data carried out by ATENEYA is subject to the principles of lawfulness, loyalty and transparency; the limitation of purposes; minimizing data and accuracy; the limitation of conservation; integrity and confidentiality and responsibility.
1. RESPONSIBLE FOR PROCESSING AND PERSONAL DATA PROTECTION
When visitors leave comments on the site, we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. Our Personnel Protection Officer (DPO) is part of our organizational structure and will be available to provide you with any information regarding the processing of your personal data by ATENEYA, including the list of our subcontractors in the field of personal data protection. You can contact the DPO by sending an email to [email protected]
2. PERSONAL DATA PROCESSED
ATENEYA Privacy and Cookies Policy sets as treatment of personal data, we understand in terms that expressly result from the Regulation “an operation or a set of operations carried out on personal data or on sets of personal data, by automated or non-automated means, such as the collection, registration, organization , structuring, conservation, adaptation or alteration, recovery, consultation, use, dissemination by transmission, diffusion or any other form of availability, comparison or interconnection, limitation, elimination or destruction ”.
Please note that the personal data collected by us, depending on your decisions regarding the services to be subscribed and the respective mode of use (hereinafter “Personal Data”).
The personal data processed through our website are as follows:
a) NAVIGATION DATA
The systems and software procedures used to operate our website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified stakeholders, but which, by its very nature, could, through processing and association with data maintained by third parties, allow users to be identified. This category of data includes IP addresses or domain names of users who connect to our website, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to send the request, request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters related to the operating system. These data are used for the sole purpose of obtaining anonymous statistical information on the use of our website and to verify its correct functioning, to identify anomalies and / or abuse and are eliminated immediately and definitively after the treatment in question. The data in question can be used to determine liability in the event of crimes against ATENEYA or third parties committed through our website.
There are several types of cookies, depending on their characteristics and functions, and these can remain on the user’s computer or mobile device for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; so-called persistent cookies, which remain on the user’s equipment until a predetermined period.
There are several cookies that can be deselected, with the exception of third party cookies in relation to which the user must refer directly to the respective modalities of marking and deselecting the respective cookies, indicated through the links:
• Essential cookies: navigation or session and strictly necessary for the functioning of the online portal or to allow the user to use the content and services requested by him.
• Cookies analytics, which allow us to understand how the online portal is used by users. These cookies do not collect information about the user’s identity or any personal data.
The information is treated in an aggregated and anonymous way.
• Functionality cookies, this is used to activate specific features of the online portal and a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.
• Profile creation cookies, used to send advertising messages in line with the preferences expressed by the user in the context of internet browsing.
• Third party cookies, that is, cookies from online portals or web servers other than those of the Holder, used for their own purposes, also including profile creation cookies. It is necessary that these third parties, listed below with the respective links to the privacy policies, are independent owners of the treatment of the data collected through the cookies served by them; therefore, the user must consult their policies for the treatment of personal data, information and consent forms (marking and unmarking the respective cookies). As a complement, it should also be noted that ATENEYA does what is reasonably required to be able to monitor cookies on its online portal. These are updated on a regular basis on the landing page at the link indicated below, where we provide transparency on cookies sent directly by ATENEYA and on their purpose, and with specific reference to cookies sent by third parties through our online portal. In relation to these cookies, we provide below the links for declarations about the privacy of third parties: to these third parties, as already noted, we assign the responsibility to provide the privacy statement and collect the consent of users. This responsibility refers not only to the cookies that the third parties send directly, but also to any additional cookies that are sent through our online portal due to the use of services from which the third parties themselves benefit. In relation to these cookies, sent by third party service providers, ATENEYA cannot exercise any control and does not know either their characteristics or their purposes.
Below are links to information about third party cookies.
ATENEYA sends only essential cookies, through its website. Some cookies are essential to access specific areas of our website. These are necessary for some areas of the site to work but are not used in any way to personally identify you. Functionality cookies are temporary and are automatically deleted once you leave the site. These cookies are essential for the proper functioning of the website.
Cookies management instructions in the main browsers:
The user may block or delete (in whole or in part) essential or functionality cookies through specific functions of his browser. However, the user is informed that the non-authorization of essential cookies may make it impossible to use the online portal, view its contents and use the respective services. Inhibiting functionality cookies may imply that some services or certain functions of the online portal are not available or do not work properly and the user may be required to change or manually enter some information or preferences each time he visits the online portal.
3. THE PURPOSE OF PROCESSING PERSONAL DATA
The processing of personal data that we intend to carry out, with your specific and express consent when necessary, has the following purposes:
a) Allow the provision of the Services requested by you, including the collection, storage and processing of data for the purposes of operational, technical and administrative management of the commercial and contractual relationship related to the provision of the Services and with a view to carrying out related communications with ATENEYA’s relationship with the customer;
b) Allow browsing and consulting the ATENEYA website;
c) Responding to requests for assistance or information, which ATENEYA may receive via email, phone or through the appropriate form available on its website. Regarding responses to requests for assistance received by ATENEYA over the phone, we inform that calls can be recorded so that ATENEYA can show that it has correctly processed your requests.
d) Comply with legal, accounting and tax obligations;
e) Send direct marketing communications (by sending electronic communications) related to services like those already subscribed by the Client, except in the case of initial opposition or in relation to subsequent communications. Please note that in the case of a legal person, ATENEYA may send electronic communications for the purposes of direct marketing relating to goods and services provided by itself or by a company of the same Group, unless the Client expressly refuses the future receipt of this type of communications and subscribe to the national list of legal persons who expressly object to receiving unsolicited communications for direct marketing purposes.
f) Prepare studies, research, market statistics; in order to be able to send advertising material, information or satisfaction surveys with a view to improving the quality of the service provided through electronic communications and / or telephone calls, or even through the official ATENEYA pages on social networks;
g) To make personalized commercial proposals based on the products or services you have purchased, or on which you have shown interest. This process is necessary for the purposes of the legitimate interest of the data controller in customizing their business proposals. You can oppose this process by sending your request to ATENEYA through the following e-mail: [email protected]
h) For the sole purpose of security and prevention of fraudulent behavior.
4. GROUND OF THE TREATMENT AND ITS MANDATORY OR OPTIONAL NATURE
The legal basis for processing personal data for the purposes indicated in points a), b) and c) of the previous clause is that set out in paragraph b) of paragraph 1 of article 6 of the Regulation, since the treatment in question is necessary for the provision of the Services subscribed by the Customer. Please note that the provision of personal data for these purposes is optional, however, failure to provide such data makes it impossible to provide the Services by ATENEYA.
The purpose indicated in point d) above translates a legitimate treatment of personal data under the terms of paragraph c) of paragraph 1 of article 6 of the Regulation, since such treatment is necessary for ATENEYA to comply with legal obligations to which it is subject.
The processing of personal data carried out for marketing purposes is based on the Client’s express and unequivocal consent, in accordance with the provisions of paragraph a) of paragraph 1 of article 6 and paragraph c) of paragraph 2 of article 22 of the Regulation. The provision of your personal data for this purpose is therefore optional. If you want to object to the processing of your personal data for direct marketing purposes, you can do so at any time by sending your request to ATENEYA through the following e-mail: [email protected]
The purpose referred to in point h) above is based on ATENEYA’s legitimate interest in detecting fraud committed against it, in accordance with the provisions of paragraph f) of paragraph 1 of article 6 of the Regulation.
5. RECIPIENTS OF PERSONAL DATA
Your personal data may be communicated, for the purposes described above, to the following entities:
a) subjects who normally act as subcontractors, that is: natural or legal persons who provide assistance and advice to ATENEYA in accounting, administrative, legal, tax and financial matters, their personal data may be communicated, for the purposes described above to the following entities : trade fairs and credit recovery; entities with whom it is necessary to interact in order to provide the Services or persons who perform technical maintenance functions (including equipment and electronic communications maintenance);
b) Entities to which ATENEYA must communicate personal data in accordance with the provisions of the applicable legislation and / or in response to requests from competent authorities, duly substantiated for the purpose;
c) Persons authorized by ATENEYA to process personal data strictly necessary to carry out operations related to the provision of the Services, which are contractually and / or legally bound to confidentiality and professional secrecy duties;
d) Business partners for specific purposes only if the Client has given his express, unambiguous and specific consent for that purpose.
You can request, in writing, a list of data controllers that ATENEYA relates to regarding your personal data, by sending your request to ATENEYA through the following e-mail: [email protected]
6. CONSERVATION OF PERSONAL DATA
Personal data processed for the purposes indicated in clause 3 will be kept for the period of time strictly necessary for the accomplishment of those same purposes.
Thus, the storage periods for the following personal data of the client are as follows:
Personal data processed for marketing purposes when the contract between ATENEYA and the personal data holders is no longer in effect: these data may be kept until the data subject revokes the consent given. However, ATENEYA has established that it must be erased two years after the provision of consent and after the termination of the service provision contract.
Personal data of customers made available when contracting: this type of personal data will be kept for ten years, if it relates to data related to the billing of services and 5 years after the termination of the contract if the justification for its conservation respects only the need for ATENEYA defend itself against a legal claim based on contractual or extra-contractual liability.
Personal data relevant to the fulfillment of tax obligations: Such data will be deleted after 10 years of conservation, under the terms of the Tax Law. And ATENEYA Privacy and Cookies Policy.
7. RIGHTS OF PERSONAL DATA HOLDERS
The Customer has the right to request ATENEYA, at any time, access to his personal data, the respective update or deletion, in accordance with the provisions of the Regulation. You also have the right to request the limitation of the processing of your personal data, in accordance with the provisions of article 18 of the Regulation, as well as the right to obtain your personal data in a structured format, in common use and readable by automatic device, in cases provided for in Article 20 of the Regulation.
The requests in question must be sent in writing to the email address: [email protected]
If you believe that the processing of your personal data violates the provisions of the applicable legislation, you can file a complaint with the competent supervisory authority, in accordance with the provisions of the Regulation.
This ATENEYA Privacy and Cookies Policy has been in effect since May 25, 2023.
ATENEYA reserves the right to modify or simply update, in part or in full, the respective content, with a view to always complying with the applicable legislation and in force. ATENEYA will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the ATENEYA website, so you should check it periodically in order to become aware of the most updated version at each moment of this Policy Privacy and on the treatment of your personal data carried out by ATENEYA.