1.1. Data Subject is a natural person about whom Placent Activ Milano has information or data enabling identification of the natural person. Data Subjects are, for example, the Clients, cooperation partners and employees who are natural persons and whose Personal Data are held by Placent Activ Milano.
1.3. Personal Data is any information concerning an identified or identifiable natural person.
1.4. Personal Data Processing is any operation or set of operations performed on the Personal Data of a Data subject. For example, collection, recording, organisation, storage, alteration and disclosure, enabling access to, consultation and retrieval, use, transmission, cross-checks, combination, restriction, erasure or destruction of Personal Data or several of the aforementioned operations, irrespective of the manner of performing these operations or the means used.
1.5. Client is any natural or legal person who uses or has expressed a desire to use the services of Placent Activ Milano.
1.6. Agreement is the Service Agreement or any other agreement entered into between Placent Activ Milano and the Client.
1.7. Website www.placentactiv.com is the website of Placent Activ Milano.
1.8. Visitor is any person using the website of Placent Activ Milano.
1.9. Child is a person under 13 years of age in the context of Personal Data Processing in the Republic of Estonia.
1.10. Services are any services and products offered by Placent Activ Milano.
1.11. Cookies are the data files sometimes recorded in the device of a Visitor of the Website.
1.12. Data Protection Officer of Placent Activ Milano is the person who monitors the implementation of the Personal Processing Principles of Placent Activ Milano and who can be contacted by the Data Subject in the case of a complaint.
1.13. Sales Channels are the means used by Placent Activ Milano for communicating with a Data Subject, a device created for selling goods and providing services, including e-mail, telephone, public and social media, various chat lines, individualised and interactive advertisements and other tools on the Website and elsewhere.
1.14. Product Portfolio means the various products and Services of Placent Activ Milano, the list of which is available at www.placentactiv.com.
2. General Provisions
2.1. Placent Activ Milano is the legal entity Aravon OÜ, registry code 11476148, registered address Aardla 25b, Tartu, 50110, Estonia
2.2. Placent Activ Milano may process Personal Data as:
2.2.1. a controller, while determining the purposes and means of processing;
2.2.2. a processor, in accordance with the instructions from the controller;
2.2.3. a recipient, to the extent to which the Personal Data are transferred.
3.1. Placent Activ Milano always takes into account the interests, rights and freedoms of Data Subjects in the processing of their personal data.
3.2. The objective of Placent Activ Milano is to Process Personal Data responsibly, based on the best practice, with the aim of always being prepared to demonstrate the conformity of Personal Data Processing to the established purposes.
3.3. All the processes, guidelines, operations and activities of Placent Activ Milano related to Personal Data Processing are based on the following principles:
3.3.1. Lawfulness. There is always a legal basis for the Processing of Personal Data, i.e. consent.
3.3.2. Fairness. Personal Data Processing must be fair, while providing a Data Subject with sufficient information and communication on how the Personal Data are Processed.
3.3.3. Transparency. Personal Data Processing must be transparent for the Data Subject.
3.3.4. Purposefulness. Personal Data is collected for legitimate purposes that have been established precisely and clearly, and will not later be processed in any manner which is in conflict with these purposes.
3.3.5. Accuracy. Personal Data are correct and will be updated as necessary, and all reasonable measures are taken to ensure that Personal Data which are incorrect in the light of the purpose of Personal Data Processing are deleted or corrected.
3.3.6. Limit of storage. Personal Data is stored in a format enabling the identification of Data Subjects only as long as it is necessary to achieve the purpose for which the Personal Data are processed. It means that if Placent Activ Milano wishes to store the Personal Data for a longer period of time than necessary for the purpose of collecting the data, Placent Activ Milano anonymises the data in such manner that the Data Subject is no longer identifiable. Placent Activ Milano stores the data received by Placent Activ Milano via a client relationship or any other similar relationship in accordance with the best practice. The data processed on the basis of consent is generally stored until the consent is withdrawn.
3.3.7. Reliability and confidentiality. Personal Data Processing is carried out in a manner that ensures the adequate security of Personal Data, including their protection against unauthorised or unlawful Processing and against accidental loss, destruction or damage, by taking reasonable technical or organisational measures. Placent Activ Milano has internal guidelines, rules for the employees and separate agreements with every processor stipulating the best practices, an on-going risk assessment and adequate technical and organisational measures for Personal Data Processing.
4. Composition of personal data
4.1. Placent Activ Milano collects, inter alia, the following types of Personal Data:
4.1.1. the Personal Data disclosed to Placent Activ Milano by the Data Subject (name, e-mail address, postal address, telephone);
4.1.2. the Personal Data generated as a result of day-to-day communication between the Data Subject and Placent Activ Milano;
4.1.3. the Personal Data manifestly made public by the Data Subject (e.g. in social media);
4.1.4. the Personal Data generated upon consumption of Services (e.g. making purchases in the web store);
4.1.5. the Personal Data generated as a result of visiting and using the Website (e.g. the time spent on the Website);
4.1.6. the Personal Data received from third persons;
4.1.7. the Personal Data created and combined by Placent Activ Milano (correspondence or order history in the context of a client relationship).
5. Composition, purposes and bases for processing personal data
5.1. Placent Activ Milano processes Personal Data only on the basis of consent or on a legal basis.
5.2. Placent Activ Milano processes Personal Data on the basis of consent precisely within the limits, to the extent and for the purposes determined by the Data Subject. As for consents, Placent Activ Milano follows the principle that every consent must be clearly distinguishable from other matters, in an intelligible and easily accessible form, using clear and plain language. Consent may be given in writing or by electronic means or as an oral statement. A Data Subject gives consent freely, specifically, informedly and unambiguously, for example by ticking a box on the Website.
5.3. Legitimate interest means the interest of Placent Activ Milano in the management and direction of its business to be able to offer the best possible Services on the market. Placent Activ Milano processes Personal Data on a legal basis only after careful consideration in order to ascertain the legitimate interest of Placent Activ Milano, based on which the Personal Data Processing is necessary and is in compliance with the interests and rights of a Data Subject. In particular, Personal Data Processing may take place on the basis of a legitimate interest for the following purposes:
5.3.1. for ensuring a trust-based relationship with a client, e.g. Personal Data Processing that is strictly necessary to determine the ultimate beneficiaries or to prevent fraud;
5.3.2. for the administration and analysis of the Client base to improve the availability, selection and quality of Services and products and make the best and more personalised offers to the Client upon the Clients consent;
5.3.3. for the identifiers and Personal Data collected upon the use of Websites, mobile applications and other Services. Placent Activ Milano uses the collected data for web analysis or for the analysis of mobile and information society services, for ensuring and improving operation, for statistical purposes and for analysing the behaviour and user experience of Visitors and for providing better and more personalised Services;
5.3.4. for the organisation of campaigns, including the organisation of personalised and targeted campaigns, carrying out Client and Visitor satisfaction surveys and measuring the effectiveness of the performed marketing activities;
5.3.5. for analysing the behaviour of the Clients and Visitors in various Sales Channels and on Websites;
5.3.6. for network, information and cyber security considerations, for example for fighting against piracy and for ensuring the security of the Websites as well as for the measures taken for making and storing backup copies;
5.3.7. for the establishment, exercise or defence of legal claims.
5.4. For performing a legal obligation, Placent Activ Milano processes Personal Data to perform the obligations set forth by law or to exercise the uses permitted by law. Legal obligations derive, for example, from adhering to the rules of payment processing and the prevention of money laundering.
5.5. If Personal Data Processing is carried out for a new purpose, different from those for which the Personal Data were originally collected, or is not based on the consent given by the Data Subject, Placent Activ Milano carefully assesses the permissibility of such new Processing.
6. Disclosure and/or transfer of client data to third persons
6.1. Placent Activ Milano cooperates with persons, to whom Placent Activ Milano may transfer data regarding the Data Subjects, including their Personal Data, in the context and for the purposes of co-operation.
6.2. Such third persons may be Placent Activ Milano’s advertising and marketing partners, companies carrying out client satisfaction surveys, debt collection agencies, credit registers, IT partners, persons, authorities and organisations intermediating or providing mail services, provided that:
6.2.1. the respective purpose and the Processing are lawful;
6.2.2. the Personal Data Processing is carried out in accordance with the guidelines of Placent Activ Milano and on the basis of a valid agreement;
7. Security of personal data processing
7.1. Placent Activ Milano stores the Personal Data strictly for the minimum period required. Personal Data with an expired storage period is destructed using the best practice and in accordance with the procedure established for this purpose by Placent Activ Milano.
7.2. Placent Activ Milano has established guidelines and procedural rules for ensuring the security of Personal Data by both organisational and technical measures.
7.3. In the case of any incident related to Personal Data, Placent Activ Milano takes all necessary measures to mitigate the consequences and hedge any relevant risks in the future. Inter alia, Placent Activ Milano registers all the incidents and informs the Data Protection Inspectorate and the Data Subject directly in prescribed cases.
8. Processing of the personal data of children
8.1. The Services of Placent Activ Milano, including the information society services, do not target Children.
8.2. Placent Activ Milano does not knowingly collect any information on persons under the age of 13 (Children) and in the case of any respective informed activity, we act on the basis of the wishes of a parent or guardian.
8.3. If Placent Activ Milano finds out that it has collected Personal Data from a Child or regarding a Child, Placent Activ Milano uses its best efforts to discontinue the Processing of the respective Personal Data.
9. Rights of data subjects
9.1. Rights related to consent:
9.1.1. A Data Subject is always entitled to inform Placent Activ Milano of their wish to withdraw consent for Personal Data Processing.
9.1.2. The consent given to Placent Activ Milano for receiving a newsletter can be cancelled via the link at the bottom of the newsletter.
9.2. A Data Subject also has the following rights upon Personal Data Processing:
9.2.1. The right to receive information i.e. the right of a Data Subject to receive information regarding the Personal Data collected about them.
9.2.2. The right to access data which, inter alia, includes the right of a Data Subject to a copy of the Processed Personal Data.
9.2.3. The right to the rectification of inaccurate Personal Data.
9.2.4. The right to the erasure of data i.e. in certain cases a Data Subject will be entitled to demand the deletion of Personal Data, for example, if the Processing is only carried out on the basis of consent.
9.2.5. The right to demand a restriction of Personal Data Processing. This right is created, inter alia, if the Personal Data Processing is not permitted under law or if the Data Subject challenges the accuracy of the Personal Data. A Data Subject is entitled to demand the restriction of the Personal Data Processing for a period enabling the processor to check the accuracy of the Personal Data or if the Personal Data Processing is unlawful but the Data Subject does not request the deletion of the Personal Data.
9.2.6. The right to the assessment of a supervisory authority on whether the Processing of the Personal Data of the Data Subject is lawful.
10. Exercising of rights and filing of complaints
10.1. Exercising of rights:
10.1.1. A Data Subject is entitled to address Placent Activ Milano by e-mailing at [email protected] in the case of any question, request or complaint related to Personal Data Processing.
10.2. Filing of complaints:
10.2.1. A Data Subject is entitled to address a complaint to Placent Activ Milano, the Data Protection Inspectorate or a court if the Data Subject is of the opinion that their rights have been infringed in Personal Data Processing.
10.2.2. The contact details of the Data Protection Inspectorate are available on the website of the Data Protection Inspectorate: http://www.aki.ee/et/inspektsioon/kontaktid-nouandetelefon.
11. Cookies and other web technologies
11.1. Placent Activ Milano may collect data regarding the Visitors of the Website and other information society services by using Cookies for this purpose (i.e. small pieces of information stored by the Visitors browser on the hard disk of the computer or any other device of the Visitor) or other similar technologies (e.g. IP address, equipment information, location information) and process these data.
11.2. Placent Activ Milano uses the collected data to enable the provision of the Service in accordance with the habits of a Visitor or Client; to ensure the best Service quality; to inform the Visitor and Client of the contents and give recommendations; to make advertisements more relevant and make marketing efforts more efficient; and to facilitate logging in and protection of data. The collected data is also used for counting the Visitors and recording their usage habits.
11.3. Placent Activ Milano uses session Cookies, persistent Cookies and advertising Cookies. A session Cookie is deleted automatically after every visit and persistent Cookies remain upon repeated use of the Website. Third party Cookies are used by the Websites of the partners of Placent Activ Milano. Placent Activ Milano does not control the generation of those Cookies, therefore information on these Cookies can be obtained from third persons.
11.5. Most of the web browsers allow Cookies. Without fully allowing Cookies, the functions of the Website are not available to a Visitor. The enabling or disabling of Cookies and other similar technologies is controlled by a Visitor via the settings of the Visitors own web browser, settings of the information society service and platforms for making such privacy more efficient.
12. Important documents, guidelines and procedures
12.1.1. The register of processing operations, which sets out all the purposes and manners of Personal Data Processing, the types and categories of the Personal Data being Processed and the respective bases for Processing;
12.1.3. The policy of the organisational and technical measures taken by Placent Activ Milano, which sets out various measures taken by Placent Activ Milano to always maintain the confidentiality and security of Personal Data;
12.1.4. All About Cookies: Descriptions of cookies and other web technologies used by Placent Activ Milano.
13. Contact details and information
13.1. The contact details of Placent Activ Milano which are important for a Data Subject:
13.1.1. Regarding Personal Data issues, Placent Activ Milano can be contacted via e-mail at [email protected]
14. Other terms and conditions