According with the European General Data Protection Regulation n. 679/2016 (G.D.P.R.) and the Decree n. 196/2003 (Italian Privacy Code), the information provided below describes the data processing and management of the information collected during the usage of the service Chino.io.
General information on data processing
Using Chino.io may result in processing data relating to identified or identifiable natural persons.
We do not knowingly attempt to solicit or receive any information from anyone under the age of 18.
The processing of personal data takes place regularly only on the basis of other legal provisions that permit data processing.
Scope of the processing of personal data
A distinction must be made between two categories of personal data:
Third parties’ data may also include personal data of a special category in accordance with Art. 9 GDPR (hereinafter "sensitive data").
We process personal data only to the extent necessary to provide a functional app.
Data Controller
In regards to Users’ data Chino Srls is the Data Controller.
In regards to third parties’ data the User is the Controller, instead Chino Srls is the Data Processor.
Chino Srls is based in Via Segantini, 28, 38068, Rovereto (Italy). Chino Srls can be contacted via email at info@chino.io .
Data Processing Agreement
Pursuant to the provisions of Article 28 of GDPR, in regards to Third Parties’ Data, the Data Controller and the Data Processor, to the extent of their respective competences, have also accepted, together with the Terms and Conditions of Service, the relevant Data Processing Agreement.
Types of Processed Personal Data
Users’ Data
Account Creation Data
When the User creates a Chino.io Account, he/she provides us with personal information that includes his/her:
• Name, Surname
• IP address
• Telephone number
• Unique Identifier (Such as E-mail)
• Usage of products and services
• Device and browser information
Data communicated by users
Sending messages, on the basis of the user’s free, voluntary, explicit choice, to our contact addresses, and filling in and sending personal information requested in the forms of various services on the website (e.g. Registration portal, mailing lists, etc.) entail the acquisition of the sender’s contact information – which is necessary to provide a reply – as well as of any and all the personal data communicated in that manner.
The absence of this information may make it impossible to fulfill the service provisioning (e.g. service billing) and therefore block such Users.
The e-mail provided by the user during registration to the website, could be used by the owner for the promotion of services similar to those to which the user has subscribed, to send to the User promotional material related only to those goods or services, or for carrying out market researches or commercial communications.
The User may object to this treatment by sending an email to unsubscribe@chino.io. This opposition does not produce any effect on service provision.
Third Parties Data
Every data that you are processing - through/storing in - the Chino.io Platform is protected by the best security measures according to best practices and guidelines provided by the European Data Protection Authorities (such as Encryption and Pseudonymisation). Chino Srls process Third Parties’ Data just to the extent that is necessary to provide the service and not for any other purpose.
Use of Cookies
We only use so-called "technical cookies" in our app, which allow us to recognize you as a user with each access. Such data is not passed on to third parties.
Purposes and legal basis of the Processing
When Chino Srls asks Customer to provide personal data, Customer can decline. Chino Srls requires some personal data to provide its service. If Customer chooses not to provide data necessary to provide him/her with a product or feature, he/she cannot use that product or feature. Likewise, where Chino Srls needs to collect personal data by law or to enter into or carry out a contract with Customer, and he/she does not provide the data, Chino Srls will not be able to enter into the contract; or if this relates to an existing product Customer is using, Chino Srls may have to suspend or cancel it. Chino Srls will notify him/her if this is the case at the time. Where providing the data is optional, and Customer chooses not to share personal data, features like personalization that use such data will not work for him/her.
Chino Srls uses the collected data to:
• provide the Chino.io service, as agreed in our Terms of Service, with its functionalities (which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request) and communicate with you regarding the platform. For this purpose we process Users’ data (acting as Data Controller) and Third Parties’ Data (acting as Data Processor accordingly to the signed Data Processing Agreement). The legal basis for the processing of Users’ Data is the necessity of fulfilling the contract in accordance with Art. Art. 6 para. 1 b) GDPR.
• analyse, develop, and improve technical functionalities of the platform, e.g. to collect and analyze usage statistics of how the platform is used. The processing of Users’ Data is based on our legitimate interest in analysing (how the platform is used)/developing/improving it.
• manage and defend legal claims. If necessary we may use Users’ Data to manage and defend legal claims, e.g. in connection with a dispute or a court proceeding. We will in such case process the Users’ Data collected which is necessary in order to manage and defend the legal claim in question. The processing is based on our legitimate interest of managing and defending legal claims.
• fulfill legal obligations. We process Users’ Data as far as this is necessary to fulfill a legal obligation, which we are subject to. Art. 6 para. 1 lit. c) GDPR, insofar as this is necessary to safeguard the legitimate interests of our company or a third party and does not outweigh the interests, fundamental rights and fundamental freedoms of the person concerned, in accordance with Art. Art. 6 para. 1 f) GDPR.
• Provide our newsletter. If we collect your e-mail address, it may be used to send you e-mail newsletters for our offers similar to the services you have already purchased, as long as you do not object to receiving such newsletters. For example, such newsletters may include updates regarding new product features, additional services or events where product demonstrations will be held. The processing is based on our legitimate interests: to improve our products and services and better engage with you, ex art. 6 par 1 lett f) GDPR and on art. 130 co. IV D. Lgs. 196/2003 (Italian Privacy Code). You can at any time unsubscribe from our newsletter by clicking on the unsubscribe link in the email. Your personal data is stored for this purpose until you choose to unsubscribe from the newsletter.
How to Access & Control Customer’s Personal Data
The Customer can also make choices about Chino Srls collection and use of her/his data and Users data. The Customer can control data that Chino Srls has obtained and exercise his/her data protection rights directly or by contacting Chino Srls support team.
The Customer can access or control his/her personal data by visiting the management page.
The Customer can also access and clear his/her data through the Chino.io privacy dashboard.
Place of data processing
The processing of data provided by registered users is done within the EEA (European Economic Area) at the Chino Srls operational offices, and by third parties that are involved in the Chino.io service provisioning.
Third Party Access to Information
According to the signed Data Processing Agreement, Chino Srls uses certain trusted parties to provide, improve, protect and promote its Services. These third parties will access Customer’s information only to perform tasks on our behalf in compliance with this Privacy Policy and Chino Srls will remain responsible for their handling of your information per its instructions.
Security Measures
The Personal data are processed by automated tools for the time strictly necessary to achieve the purposes for which they were collected.
We are committed to protecting your Data and to taking appropriate technical and organisational security measures to protect it from unauthorised or unlawful processing and from accidental loss, destruction or damage. These security measures are constantly updated in accordance with the latest technological developments and guidelines provided by the European Data Protection Authorities.
Data Retention
Cancellation or deactivation of the accounts: if you would like to request the cancellation or deactivation of your account, you should contact our support team for assistance. Cancellation or deactivation of your account does not ensure complete or comprehensive removal of the content or information you may have posted or otherwise made available publicly on the service while you were a registered user.
We will retain personal information for as long as is needed to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law (such as a tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process the collected personal information, we will either delete or anonymize it, or, if this is not possible ( for example because all the personal information has been stored in backup archives), then we will securely store the personal information and isolate it from any further processing until the deletion is possible.
For personal information that we process on the behalf of our users we will retain such personal information in accordance with the terms of our agreement with them, subject to applicable law.
Data Subjects’ Rights
Data subjects have the right to obtain from Chino, where appropriate: to access to their personal data and to rectify or delete of the same; to restrict the processing that concerns them; to receive a copy of the processed data in a standardised format in case they wish to transfer it to another controller (data portability) (pursuant to Articles 15 ss. of the Regulation). Data subjects also have the right to object to the processing at any time in the cases provided for. Chino does not make automated individual decision-making and profiling.
The appropriate requests must be submitted by contacting the Data Controller by email to the following address: legal@chino.io
Right to lodge a complaint
Data subjects, who believe that the processing of personal data referred to them in accordance with this privacy policy is in violation of the provisions of the Regulation, have the right to lodge a complaint with the Garante per la Protezione dei Dati Personali (the Italian Data Protection Authority), as provided for in art. 77 of the Regulation itself, or to take appropriate legal action (art. 79 of the Regulation).
Changes to Privacy Policy
Chino Srls reserves the right to make changes to this privacy policy at any time by giving notice to its users via email.
Your continued use of our services constitutes your agreement to the updated privacy policy on a prospective basis.
If you have any privacy concern regarding this Policy or how Chino Srls manages your data, please send us an email to: legal@chino.io