Enforcement Date: January 1st 2021.
2. WHAT KIND OF PERSONAL DATA DOES SPEAKANDO COLLECT?
The Firm collects registration data when the user registers for a Service provided by the Firm.
Namely, the Firm collects the following types of user data:
- Registration Data: the information sent when registering for a Service provided by the Firm. Registration Data may include, for instance, name, surname, email address, gender, country, ZIP code, and date of birth.
Speakando does Not collect:
- Sensitive information: please do not send us or reveal any sensitive personal data (e.g. social security ID, information related to your ethnic origin, political or religious opinion, Trade Union affiliation) through the Firm’s Services or by any other means.
3. WHY DOES SPEAKANDO COLLECT PERSONAL DATA FROM USERS?
Speakando uses personal data collected from the user to:
a) Provide the Firm’s services and other features;
b) Measure and improve the quality of the Firm’s services and features;
c) Improve user experience both online and offline with reference to the Firm’s Services, by providing more relevant and interesting content;
d) Protect the rights of the Firm, protect the safety, privacy and security of the Firm’s users and people in general;
e) Comply with the law and legal requirements and/or answer requests from the government or public authorities.
4. WHAT ARE THE LEGAL BASES FOR PERSONAL DATA PROCESSING?
The processing of personal data for the purposes stated in:
Consent to the processing of personal data for the purposes stated in Section 3 can be withdrawn at any time by sending an email to the address specified in Section 11.
5. HOW DOES SPEAKANDO PROCESS THE USER’S PERSONAL DATA?
As for the above mentioned purposes, data are processed by electronic and manual means, and are protected through adequate security measures, taking into account state of art, implementation costs and the nature, range, context and purposes of the processing, as well as the risk of varied probability and seriousness in terms of the rights and freedoms of individuals. With reference to the above, Speakando takes appropriate administrative, technical, physical and personnel measures to protect the personal data held by Speakando against loss, theft, and unauthorized use, disclosure or modification.
6. WHO CAN ACCESS THE USER’S PERSONAL DATA?
- Third-party service providers who are in charge of data processing activities and duly appointed as external Data Processors when required by applicable law. This category includes, for instance, cloud service providers, other companies in the group, instrumental or support service providers for Speakando’s services – including but not limited to: companies providing IT services, experts, consultants and lawyers;
- Business partners. Subject to an authorization, Speakando may share personal data with business partners operating in the language industry, to send marketing communication;
- Competent national authorities, in order to comply with applicable law.
7. ARE PERSONAL DATA TRANSFERRED ABROAD?
Personal Data may be transferred to countries within the European Economic Area or outside of the European Economic Area.
8. WHAT ARE THE USER’S RIGHTS WITH REFERENCE TO THEIR PERSONAL DATA?
At any time, the user has the right to:
a) Receive a confirmation of whether any of their personal data are held, and be informed of their content and source. To verify the accuracy of data or request correction, update or modification of data;
b) Request deletion, conversion into anonymous form or limitation of any personal data processed in violation of applicable law;
c) Opt out from data processing, in any case, for legitimate reasons.
Please note that if you request the deletion of personal data, copies of some account information may be kept visible in some circumstances (e.g., when sharing information on social media or other services, or, for example, when keeping those copies is mandatory by law or necessary to comply with legal defense obligations).
You can opt out at any time from:
Moreover, from May 25th, 2018, additional rights are effective, as described in Section 9 below.
9. FROM MAY 25th 2018, THE FOLLOWING PROVISIONS APPLY:
On May 25th 2018, the Privacy Regulation is enforced and the following provisions apply:
A. Retention period for the user’s personal data
At the end of the retention period, personal data will be deleted, converted into anonymous data or aggregated.
B. Additional rights
a) Request Speakando to limit the personal data processing in case:
- The user has an objection to the accuracy of personal data, until Speakando takes effective measures to correct the data or verify their accuracy;
- The data have been processed illegally, but the user does not want Speakando to delete the data;
- Speakando does no longer need the personal data to pursue the processing purposes, but the user requests their personal data for the establishment, exercise or defence of legal claims;
- The user has opted out from the processing justified by reasons of legitimate interest, while waiting to verify that Speakando has legitimate grounds to continue the processing.
b) Opt out from personal data processing;
c) Request the deletion of personal data without undue delay;
d) Receive an electronic copy of the personal data provided by the user, if the user wants to transfer personal data to themselves or to another provider (“data portability”), when personal data are processed by automatic means and the processing is (i) consent-based, or (ii) necessary for the provision of Speakando’s services;
e) Lodge a complaint before the competent supervisory authority.
TYPES OF DATA PROCESSED AND PROCESSING PURPOSES
1.1 General information on cookies
Cookies are small text files that the websites visited by users send to their terminals (usually the browser), where they are stored to be retransmitted by the terminals to the same websites each time the user visits those websites again. Furthermore, each website can allow the transmission of ‘third-party cookies’, which are cookies generated by other websites than the one the user is navigating (through objects added to the website, such as banners, images, maps, sounds, specific links to other domains’ webpages).
Depending on their duration, they are divided into: session cookies, which are temporary cookies that are automatically deleted from the terminal at the end of the navigation session, by closing the browser; and persistent cookies, which are stored in the terminal until they expire or are eliminated by the user.
Cookies have different purposes. They are especially used for the transmission of communication or to provide the service required by the user. Namely, they allow to enable and optimize the website functions, perform computerized authentication, and prevent misuse, monitor sessions, improve the user’s navigation experience, e.g. by keeping the connection to personal areas active during navigation through the webpages without having to reinsert User-ID and password, and memorizing specific information regarding users (including preferences, browser type, computer type).
The latter are called “technical cookies” (the user consent is not required for their use), because without them, some of the above mentioned operations could not be performed or would be more complex and/or non-secure.
In any case, cookies can be read or modified only by the website generating them; they cannot be used to retrieve any data from the user’s terminal and cannot transmit IT viruses. Some of the cookies’ functions can also be performed by other technologies; therefore, the term ‘cookie’ hereby refers to cookies and all other similar technologies.
Speakando.net may use session cookies and persistent cookies. The types of cookies directly generated by Speakando.net are technical cookies, used for authentication and management of the navigation session (e.g. to identify and validate the user’s access to a Personal Area).
1.3 Third-party cookies
a) social media, managing cookies to allow content sharing between logged-in members, through plug-ins. Namely:
b) subjects providing services used by Google to collect statistics and aggregated information on the users visiting this website. Speakando uses the following services:
Google Analytics (http://www.google.com/intl/it/policies/privacy/),
Youtube Embed (http://www.google.it/intl/it/policies/privacy/).
1.4 Managing the user’s choice on cookies
Cookies may be managed by the user through their browser.
The user can manage their preferences related to cookies through the features provided by common browsers (Internet Explorer, Edge, Mozilla Firefox, Google Crome, Apple Safari), which allow the user to delete/remove cookies (all or some of them) or to change the browser settings in order to block cookies or limit them to specific websites. To learn how to set up the browser’s setting (usually accessible through the Tools bar), please go to the Support webpages of the browser providers (you can find them through a search engine).
Disabling cookies does not prevent per se the user from using Speakando.net’s services; however, if all cookies are deleted/blocked, including technical cookies, some operations may not be performed or may be more complex and/or non-secure, e.g. performing activities within the website’s Personal Area (indeed, cookies allow the user to be identified throughout the session).
2. Navigation Data
In order to allow this website to work, IT systems and software procedures acquire some personal data during normal operations. Personal data are implicitly transmitted by using the Internet communication protocols.
This kind of information is not collected to be associated to identified users, but, due to its nature, the information may be processed with data hold by third parties and allow the user/visitor to be identified (e.g. IP address, domain names of computers used by users who connect to the website, the code indicating the server data response status, browser type, etc.).
Such data are only used to provide statistics (therefore, they are anonymous) and to check the correct functioning of the website. Anyway, web contact data are not stored longer than six months, except in case of investigations related to cyber crimes perpetrated against this website.
No data deriving from the web service will be shared or disclosed.
3. Data provided by users/visitors on a voluntary basis
When users/visitors connect to this website and send their personal data to access specific services, or to send requests via email, or to take part in personnel recruitment procedures, the operation requires the acquisition of the sender address and/or other personal data, which will exclusively be processed for the purposes of answering the request, or to provide the service requsted or for the selection of personnel.
The personal data provided by the users/visitors will only be shared with third parties if sharing is necessary to meet the users’/visitors’ requests.
MODE OF PROCESSING
The processing is performed through IT tools and/or manually (e.g. on paper) for the time that is strictly necessary to pursue the purposes for which the data have been collected. In any case, the processing will comply with the applicable law.
OPTIONAL SUPPLY OF DATA
Apart from what was specified for navigation data, users/visitors are free to provide their personal data. In case they fail to do so, the only consequence can be the unavailability of the service requested.
DATA CONTROLLER, PROCESSORS, AND CATEGORIES OF APPOINTED PERSONNEL
The Data Controller is Silvia Cicciomessere.
RIGHTS OF THE PERSONS CONCERNED
Users/Visitors have the right to access at any time to the data concerning them and to exercise other rights (request the source of data, the correction, update, or integration of inaccurate or incomplete data, or the deletion or block of data processed in violation of the law, o to opt out from the use of data for legitimate reasons) as per article 7 of the Privacy Code, by sending an email to the following address: firstname.lastname@example.org