Privacy Policy

Pursuant to current legislation under the EU Regulation 2016/679 and in relation to the personal data concerning you and which will be processed, we inform you of the following.
According to the legislation indicated, the processing of your personal data will be based on the principles of correctness, lawfulness, relevance, transparency and protection of your privacy and your rights.
In this privacy statement we describe the ways in which we collect, process, use and disclose information that we obtain through our portal, as well as through our content-discovery platforms, feeds, widgets, analytical tools and other technological applications that we can provide both through our Sites both through third party websites.

1. TYPES OF SUBJECTS, PURPOSE AND LEGAL BASIS OF DATA PROCESSING

The data processing differs according to the categories of subjects who come into contact with www.nativery.com.

Users can be Customers and Partners and Business Partners, Visitors or Users.

1. Customers (Advertiser) and Business Partners (Publisher)
We collect information about our customers and partners directly from them. For example, we collect a customer or a commercial partner's contact data when he establishes a contractual relationship with Nativery and we collect a username and password when a customer or a partner creates an account (we can, at this stage, collect information such as name, e-mail address, number by telephone, payment card information, billing information and any other information that the customer can decide to provide us on the platform). When a customer or a partner sends us an email to ask us questions or signs up to receive our email newsletters, we collect the information that the customer or the partner sends us. We will also collect other information that Customers and Partners choose to provide us, such as the contents of a message that a Customer transmits through our Sites or via e-mail. We can also collaborate with third-party suppliers to process payments on behalf of our Clients and Partners or from them on our behalf. We will not have access to the Information you provide to such third parties, however encouraging you to view their privacy policies to learn about their practices.
2. Users
We automatically collect information about users when users interact with our services displayed on the websites and digital properties of our customers and partners. Like most web-based services, we collect this information relating to customers and partners through cookies and other technologies. The data collected, however, by Nativery are pseudonymised, that is, they do not allow us to know the personal data that allow you to connect the user to a physical identity (name, surname, email ...), but only information relating to the device and the system operating in use to the user, the IP address, the web pages to which the Users have accessed the websites of our Customers and Partners, the link that led a User to a Customer's website, the date and time when a User logged in to a Customer website, information on events (e.g., system lockups), and general location information (e.g., city and state).
3. Visitors
When a person makes use of our Sites, information are collected directly from the same or from third parties who collect this information automatically. We can combine all the information we collect from different sources.
We may collect Visitor Information directly from them (for example when an email is sent to us for information, or to subscribe to the Nativery newsletter). We can also use the scripts (codes) of third-party data analysis tools to record your data input in those fields before transmitting them. We may also collect any other information that you choose to provide us, such as the contents of a message that you transmit through our sites. We may collect information relating to visitors concerning you from third parties who automatically and on our behalf collect information through its use. of the Site, such as web data analysis companies.
The treatment
a) is aimed at activating the services offered by the portal and managing requests or registrations to initiatives reserved for registered users; legal basis of the processing is the need to execute requests from the data subject. (concerns Customers and Partners, Users and Visitors)
b) with your express consent is aimed at communicating, via e-mail or otherwise, with Customers on their accounts; respond to requests for information, requests or complaints from customers and inform them by sending news, best practices, or other useful or interesting information, in accordance with their preferences regarding communications; the legal basis of the processing is the consent of the data subject. (concerns Customers and Partners)
c) with your express consent, it can be aimed at providing customers with newsletters, special offers and promotions, including via e-mail; contact customers in relation to the products or services that we believe may be of interest to them; and for other marketing, advertising, promotional and general updates on Nativery. These communications will be sent in accordance with our customers' communications preferences; the legal basis of the processing is the consent of the data subject. (concerns Customers and Partners and Visitors)
d) with your consent it can be carried out to personalize the contents and information sent by us to Users or viewed by them; reformulate content to Users through our Services and elsewhere; and, in any case, personalize your experiences when using our Services; the legal basis of the processing is the consent of the data subject. (concerns Users and Visitors)
e) with your consent, it can be carried out to perfect a unique user experience on multiple browsers and devices (such as smartphones, tablets, or other display devices), offering more targeted advertising campaigns according to the characteristics of a specific user; the legal basis of the processing is the consent of the data subject. (concerns Users and Visitors)
f) with your consent it can be done to better understand how Customers, Users, and Visitors access and use our Site and our Services, both on an aggregate and on an individual basis; satisfy the requests and preferences of Customers, Users, and Visitors, and for other purposes of research, analysis or statistics; the legal basis of the processing is the consent of the data subject. (concerns Customers and Partners, Users and Visitors)
g) can be directed to trace the perpetrators of any offenses only in case of specific requests and on behalf of the competent authorities; legal basis of the treatment is the protection of the rights of the owner in relation to legal obligations. (concerns Customers and Partners, Users and Visitors)
h) This site uses services and interactions with external platforms in order to offer the best browsing experience. These external services and platforms may collect for the Owner information, always anonymous and never identifying, about user behavior. Likewise, these external services and platforms may collect some user data, governed directly by their privacy settings. (concerns Users and Visitors)
Following the owner specifies these services and platforms:

- INTERACTION WITH SOCIAL NETWORKS AND EXTERNAL PLATFORMS
These services allow you to make interactions with social networks, or with other external platforms, directly from the pages of this Site. The interactions and information acquired from this Site are in any case subject to the User's privacy settings relating to each social network. In the event that an interaction service with social networks 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.

LinkedIn button and social widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are interaction services with the LinkedIn social network, provided by LinkedIn Corporation.
Personal data collected: Cookies and Usage data.
Place of treatment: USA – Privacy Policy.

STATISTICS
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.

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 advertising network.
Personal data collected: Cookies and Usage data.
Place of treatment: USA – Privacy Policy – Opt Out

DISPLAY OF 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 to 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.
Personal data collected: Cookies and Usage data.
Place of treatment: USA– Privacy Policy

2. DATA PROCESSING METHODS AND DATA STORAGE TIME
Data Processing:
a) is performed via operations or sets of operations as defined in applicable law: collection, recording and organisation; processing, including alteration, alignment, combination; use, including consultation, disclosure, selection, extraction; blocking of disclosure, erasure, destruction; security, protection, including availability, confidentiality, completion, protection;
b) is performed by electronic or automated means, with the insertion and collection of data in electronic databases belonging to Nativery Srl, through which operations listed in a) are then conducted;
c) is also performed to complete and enhance the data collected with freely and lawfully available data, by non-electronic means and organised in paper-based filing systems;
d) is performed directly by the controller’s organisation, as well as possibly by third parties to provide services to their clients.
e) data collected to perform activities for the purposes described can be transferred abroad in accordance with the rules provided for in applicable law, by taking all appropriate precautions to ensure an adequate level of protection of said data.
Data will be processed by internal and external officers and by those assigned by the controller to perform activities for the purposes described above. Specifically, data can be made available to third-parties that perform outsourcing services on behalf of Nativery SRL, to companies that provide commercial information and are authorised to access public offices, registers and bulletins and to banks for the purposes provided for by law. Identifying data of assigned processors will be available at the headquarters of Nativery Srl.
Data provided by the data subject can be consulted by banks where lawfully available and used to update, rectify and complete information already provided and to verify compliance with requirements to access specific benefits and advantages.
Moreover, personal data can be disclosed to third parties and to government departments in order to comply with contractual obligations and the law.
Data will be stored as long as necessary for the pursued purposes, in accordance with legal obligations and restrictions provided for by law regarding data erasure.

3. COOKIES
For more information on how we use cookies and other monitoring mechanisms on the Sites and in providing our Services, please consult our Cookie Policy. You can disable some tracking features as indicated in our Cookie Policy (e.g., by disabling cookies).

4. PROVISION OF DATA
Without prejudice to the personal autonomy of the data subject, the provision of personal data can be:
a) mandatory according to law, regulation or community legislation;
b) strictly necessary for the activation and execution of the services offered, as well as for the fulfillment of tax and accounting charges;
c) optional for the purpose of carrying out information, marketing and performance promotion activities for the data subject.
The owner means that any error in the communication of the data deemed mandatory (letter ab) may make it impossible for the owner to guarantee the adequacy of the treatment with the contractual agreements for which it is performed, as well as the mismatch of the results of the treatment itself the obligations imposed by law.
d) we also specify that in the event of the provision of data and consent at any time you can exercise the rights provided for in point 9 below and that any consent given in relation to the reception of messages with traditional or automated tools can be revoked or limited to only one of the communication channels indicated above.

5. REFUSAL TO PROVIDE DATA
Any refusal by the data subject to provide personal data
a) in the cases referred to in point 1, lett. a), makes it impossible to use the services offered by the portal;
b) in the case referred to in point 1, lett. b), c), d), e) and f), does not entail any consequence on the legal relationships in place or in the process of being set up, but precludes the possibility of carrying out information and promotion activities of any other initiatives towards the data subject.

6. DISCLOSURE OF DATA
a) With your express consent, personal data may be communicated to companies affiliated and / or controlled by Nativery SRL to carry out the processing for the purposes described in this Privacy Policy.
b) with your express consent, personal data may also be communicated to sellers, service providers, agents, contractors, or other subjects who perform functions on our behalf (e.g., maintenance services, data analysis, relationship management with customers, e-mail marketing, surveys, credit card payment processing, data hosting, fraud detection);
c) customer information may be disclosed to other customers where relevant for the service we provide. For example, we can provide publishers with information about which advertisers may appear on their network or information to advertisers on the publishers' websites on which they have appeared; we can provide advertisers with information on the display and click patterns of the content they publish and we can provide advertisers with information on conversion rates for web data analysis purposes.
The data provided may be transferred to countries belonging to the European Union and to non-EU countries, in order to fulfill the aforementioned related purposes. The data will be transferred according to Article 44 - General principle for the transfer; Article 45 - Transfer based on an adequacy decision; Article 46 - Transfer subject to adequate guarantees, specifically the data will be transferred:
- to third countries or international organizations for which the Commission intervened with an adequacy assessment (art.45 EU Reg. 2016/679)
- to third countries or international organizations that have provided adequate guarantees and with which the data subject has operable rights and effective means of remembrance (art.46 EU Reg. 2016/679, also with contractual clauses and the other provisions of Article 46 (3)
- to third countries or international organizations on the basis of derogations in specific situations (art.49 EU Reg. 2016/679).

7. DISSEMINATION OF DATA
Personal data are disseminated to the subjects indicated in point n.6.
Any further communication than those indicated above and any further dissemination will take place only with your explicit consent.
8. DATA CONTROLLER AND DATA PROTECTION OFFICER
The data controller is Nativery SRL in the person of its pro tempore legal representative
The identification data of the person responsible for the processing of personal data can be acquired at the headquarters of the company Nativery SRL with headquarters in Turin, (TO)Via Vittorio Alfieri n.11.
You can request cancellation by writing to Nativery SRL Via Vittorio Alfieri n.11 10121 Turin (TO) or by sending a specific email to the address: responsibleprivacy@nativery.com.
The company has designated, pursuant to art. 37 GDPR, a data protection officer. The DPO can be contacted at the email address in charge: dpo@nativery.com

9. DATA SUBJECT'S RIGHTS
Within the limits and under the conditions provided by law, the owner has the obligation to respond to the requests of the data subject regarding the personal data concerning him. In particular, based on current legislation:
a) The data subject has the right to obtain from the data controller confirmation that personal data concerning him or her is being processed and, in this case, to obtain access to personal data and to the following information:
• the purposes of the treatment;
• the categories of personal data in question;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if recipients from third countries or international organizations;
• whenever possible, the expected retention period of personal data or, if not possible, the criteria used to determine this period;
• the existence of the right of the data subject to ask the data controller to rectify or delete personal data or limit the processing of personal data concerning him or to oppose their treatment;
• the right to lodge a complaint with a supervisory authority;
• if the data are not collected from the data subject, all information available on their origin;
• the existence of an automated decision-making process, including profiling
b) The data subject has the right to obtain from the data controller the correction of inaccurate personal data concerning him without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, also by providing an additional declaration.
c) The data subject has the right to obtain from the data controller the deletion of personal data concerning him without undue delay and the data controller has the obligation to delete personal data without undue delay within the limits and in the cases provided for by the current legislation legislation. The data controller informs each of the recipients to whom the personal data have been transmitted of any corrections or cancellations or limitations of the treatment within the limits and in the forms provided for by current legislation.
d) The data subject has the right to obtain the limitation of the processing from the data controller.
e) The data subject has the right to receive in a structured format, commonly used and readable by an automatic device, the personal data concerning him provided to a data controller and has the right to transmit such data to another data controller without impediments on the part of the data controller to whom it provided them.

10. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy is effective from 20 April 2020.
We may make changes to this Privacy Policy from time to time, so be sure to check it periodically. We will post any changes to this Privacy Policy on our Sites.
If we make changes to this Privacy Policy that substantially affect our practices compared to the information we have collected from you in the past, we will do our best to give you prior notification, highlighting these changes on our Sites. For any substantial change, we will try to obtain your prior consent if this is prescribed by the applicable data protection legislation.

This version of the notice on personal data processing was updated on 20 April 2020.