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Promo In Transfer is a data transfer service.

The service allows you to upload up to 3 GB for free and offers paid packages to take advantage of even more features! Promo In Transfer is an online service created by Promo In S.r.l.

Advertising & Marketing
Promo In Transfer offers advertising space on its website, allowing the end customer to advertise their business or product at advantageous prices.
For information, you can contact [email protected].

I – INFORMATION RELATING TO THE SITE'S PRIVACY POLICY

This section contains information on how to manage the Newsletter with reference to the processing of user data by Promo In S.r.l.
This information is also valid for the purposes of art. 13 of Legislative Decree no. 196/2003, Code regarding the protection of personal data, and for the purposes of art. 13 of EU Regulation no. 2016/679, concerning the protection of individuals with regard to the processing of personal data as well as the free circulation of such data, for subjects who interact with Promo In S.r.l. and can be reached at the address corresponding to the initial page: www.promoin.it
The information is valid only for Promo In S.r.l. and not for other websites that may be consulted by the user through links contained therein.
The purpose of this document is to provide information on the methods, timing and nature of the information that the data controllers must provide to users when connecting to the web pages of Promo In S.r.l., regardless of the purpose of the connection itself, according to Italian legislation and European.
The information may undergo changes due to the introduction of new regulations in this regard, therefore the user is invited to periodically check this page.
If the user is under the age of sixteen, pursuant to art. 8, ch. 1 EU regulation 2016/679, he will have to legitimize his consent through the authorization of his parents or guardians.

II- DATA PROCESSING

Data owner

The data controller is the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data. He also takes care of the security profiles.
With regard to this website, the data controller is Promo In S.r.l. and for any clarification or exercise of the user's rights, he can contact him at the following email address: [email protected]
Responsible for data processing

The data controller is the natural or legal person, public authority, service or other body which processes personal data on behalf of the data controller.
Pursuant to article 28 of EU Regulation no. 2016/679, upon appointment of the data owner, the data processing manager of the Promo In S.r.l. is: Marco Ruggeri
Place of data processing
The processing of data generated by the use of the Newsletter takes place at Ufficio Promo In S.r.l. in via Demetriade 79, 00178, Rome
If necessary, the data connected to the newsletter service can be processed by the data controller or data subjects appointed for this purpose at the relevant office.

III – COOKIES

Type of cookies

The Promo In S.r.l. uses cookies to make the user's browsing experience easier and more intuitive: cookies are small strings of text used to memorize some information that may concern the user, his preferences or the internet access device (computer, tablet or mobile phone) and are mainly used to adapt the functioning of the site to the user's expectations, offering a more personalized browsing experience and memorizing the choices previously made.
A cookie consists of a small set of data transferred to the user's browser from a web server and can only be read by the server that made the transfer. It is not executable code and does not transmit viruses.
Cookies do not record any personal information and any identifiable data will not be stored. If you wish, you can prevent the saving of some or all cookies. However, in this case the use of the site and the services offered could be compromised. To proceed without changing the options relating to cookies, simply continue browsing.
Below are the types of cookies that the site uses:

Technical cookies

There are numerous technologies used to store information on the user's computer, which is then collected by other sites. Among these the best known and used is HTML. They are used for navigation and to facilitate access and use of the site by the user. They are necessary for the transmission of communications on the electronic network or for the supplier to provide the service requested by the customer.
The settings to manage or disable COOKIES may vary depending on the internet browser used. In any case, the user can manage or request the general deactivation or cancellation of cookies by changing the settings of his internet browser. This deactivation can slow down or prevent access to some parts of the site.
The use of technical cookies allows safe and efficient use of the site.
COOKIES that are inserted into the browser and retransmitted via Google Analy

tics or through the statistics service of bloggers or similar are technical only if used for the purpose of optimizing the site directly by the owner of the site itself, who will be able to collect information in aggregate form on the number of users and on how they visit the site. Under these conditions, for COOKIES Analytics the same rules apply, in terms of information and consent, provided for technical cookies.
From the point of view of duration, temporary session cookies can be distinguished which are automatically deleted at the end of the browsing session and are used to identify the user and therefore avoid logging into each page visited and the permanent ones which remain active in the PC until they expire or cancellation by you.
Session cookies may be installed in order to allow access and permanence in the reserved area of the portal as an authenticated user.
They are not stored permanently but exclusively for the duration of navigation until the browser is closed and disappear when the same is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server necessary to allow safe and efficient exploration of the site.
Third party cookies

In relation to the origin, the cookies sent to the browser directly from the site you are visiting and those of third parties sent to the computer from other sites and not from the one you are visiting can be distinguished.
Permanent cookies are often third-party cookies.
Most third-party cookies consist of tracking cookies used to identify online behavior, understand interests and therefore customize advertising offers for users.
Analytical third-party cookies may be installed. They are sent from domains of the aforementioned third parties external to the site.
Third-party analytical cookies are used to detect information on user behavior on Promo In S.r.l.. The detection takes place anonymously, in order to monitor performance and improve the usability of the site. Third-party profiling cookies are used to create user profiles on Promo In S.r.l., in order to propose advertising messages in line with the choices expressed by the users themselves.
The use of these cookies is governed by the rules established by the third parties themselves. Therefore, users are invited to read the privacy information and the indications for managing or disabling cookies published on the relative web pages.
Profiling cookies

Profiling cookies create user profiles and are used to send advertising messages in line with the preferences expressed by the user while surfing the net.
When these types of COOKIES are used, the user must give explicit consent.
Article 22 of EU Regulation 2016/679 and article 122 of the Data Protection Code will apply.

IV- DATA PROCESSED

1. Data processing methods

Like all websites, this site also makes use of log files in which information collected in an automated manner is kept during user visits. The information collected could be the following:
Internet protocol (IP) address;

–              Type of browser and parameters of the device used to connect to the site;

–              Name of the internet service provider (ISP);

–              Visit date and time;

–              Web page of origin of the visitor (referal) and exit;

–              The number of clicks, if any.

The aforementioned information is test rate in an automated form and collected in an exclusively aggregated form in order to verify the correct functioning of the site and for security reasons. This information will be test rates based on the legitimate interests of the owner.
For security purposes (anti-spam filters, firewalls, virus detection) the automatically recorded data may possibly also include personal data such as the IP address, which could be used, in accordance with applicable laws, in order to block attempts to damage to the site itself or to cause damage to other users or harmful activities or activities constituting a crime. These data are never used for the identification or profiling of the user, but only for the purpose of protecting the site and its users, this information will be used on the basis of the legitimate interests of the owner.
If the site allows the insertion of comments, or in the case of specific services requested by the user, including the possibility of sending the Curriculum Vitae for a possible working relationship, the site automatically detects and records some identification data of the user, including the email address. These data are intended voluntarily for

provided by the user at the time of the request for service provision. By inserting a comment or other information, the user expressly accepts the privacy information and, in particular, agrees that the contents inserted are freely disclosed to third parties as well. The data received will be used exclusively for the provision of the requested service and only for the time necessary for the provision of the service.
The information that users of the site will deem to make public through the services and tools made available to them, are provided by the user knowingly and voluntarily, exempting this site from any liability regarding any violations of the law. It is up to the user to verify that they have permission to enter personal data of third parties or contents protected by national and international standards.
2. Purpose of data processing

The data collected by the site during its operation are used exclusively for the purposes indicated above and kept for the time strictly necessary to carry out the specified activities and, in any case, no later than 2 years.
The data used for security purposes (blocking attempts to damage the site) are kept for the time strictly necessary to achieve the previously indicated purpose.
3. Data provided by the user

As indicated above, the optional, explicit and voluntary sending of e-mails to the addresses indicated on this site entails the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the message.
Specific summary information will be progressively reported or displayed on the pages of the site set up for particular services on request.
4. Support in configuring your browser

The user can also manage cookies through the settings of his browser. However, deleting cookies from your browser could remove the preferences you have set for the site. For more information and support, you can also visit the specific help page of the web browser you are using:
internet explorer
firefox
Safari
Chrome
Opera
5.Social Network Plugins

This site also incorporates plugins and/or buttons for social networks, in order to allow easy sharing of content on your favorite social networks. These plugins are programmed so as not to set any cookies when accessing the page to safeguard user privacy. Eventually cookies are set, if so provided by social networks, only when the user makes effective and voluntary use of the plugin. Keep in mind that if the user browses being logged into the social network then he has already consented to the use of cookies conveyed through this site when registering with the social network.
The collection and use of the information obtained through the plugin are governed by the respective privacy policies of the social networks, to which please refer:
Facebook: https://www.facebook.com/help/cookies
Twitter: https://support.twitter.com/articles/20170519-uso-dei-cookie-e-d-altre-tecnologie-simili-da-parte-di-twitter
Google +: https://www.google.com/polices/techonologies/cookies
Pinterest: https://about.pinterest.com/it/privacy-policy
AddThis: https://www.addthis.com/privacy/privacy-policy
Linkedin: https://www.linkedin.com/legal/cookie/policy

V- USER RIGHTS

The art. 13 co. 2 of the EU Regulation of 2016/679 lists the user's rights.
This Promo In S.r.l. therefore intends to inform the user about the existence:
– the right of the interested party to ask the owner for access to personal data (Article 15 of the EU Regulation), their updating (Article 7, paragraph 3, letter a of Legislative Decree 196/2003), rectification (art. 16 EU Regulation), the integration (art. 7, co. 3 lett. a Legislative Decree 196/2003), the limitation of the treatment that concern him (art. 18 EU Regulation) or to oppose, for reasons legitimate, to their treatment (art. 21 EU Regulation), in addition to the right to data portability (art. 20 EU Regulation);

– the right to request cancellation (art. 17 EU Regulation), transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data are been collected or subsequently processed (art. 7 co. 3, letter b of Legislative Decree 196/2003);

– the right to obtain the attestation that the updating, rectification, data integration, cancellation, data blocking, transformation operations have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible or involves the use of means manifestly disproportionate to the protected right (Article 7, paragraph 3, letter c

of Legislative Decree 196/2003).

Requests can be sent to the data controller at his aforementioned email address (without formalities) or by using the model provided by the Guarantor for the protection of personal data.
If the treatment is based on the art. 6 paragraph 1 letter a – express consent to use – or on art. 9 paragraph 2 letter a – express consent to the use of genetic, biometric, health-related data revealing religious, philosophical beliefs or union membership, revealing racial or ethnic origin, political opinions – the user has the right to revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given before the revocation.
Likewise, in the event of a violation of the law, the user has the right to lodge a complaint with the Guarantor for the Protection of Personal Data, as the authority in charge of monitoring data processing in the Italian State.
For a more in-depth examination of your rights, see articles 15 et seq. Of the EU Regulation 2016/679 and the art. 7 of Legislative Decree 196/2003.

VI - FULFILLMENTS

The holder notifies the Guarantor of the processing of personal data which he intends to proceed, only if the treatment concerns:
– genetic, biometric data or data indicating the geographical position of persons or objects via an electronic communication network;

– data suitable for revealing the state of health and sexual life, processed for the purpose of assisted procreation, provision of health services via telematics relating to databases or the supply of goods, epidemiological surveys, detection of mental, infectious and diffusive diseases , seropositivity, organ and tissue transplantation and monitoring of health expenditure;

– data suitable for revealing sexual life or the psychic sphere, processed by non-profit associations, bodies and organizations, even if not recognised, of a political, philosophical, religious or trade union nature;

– data processed with the aid of electronic tools aimed at defining the profile or personality of the interested party or at analyzing consumption habits and choices or at monitoring the use of electronic communication services with the exclusion of processing that is technically essential to provide the services same to users;

– sensitive data recorded in databases for personnel selection purposes on behalf of third parties as well as sensitive data used for opinion polls, market research and other sample research;

– data recorded in special databases managed with electronic tools and relating to the risk of economic solvency, the financial situation, the correct fulfillment of obligations, illicit or fraudulent conduct.

VI – SECURITY OF THE DATA PROVIDED

This site processes user data in a lawful and correct manner, adopting the appropriate security measures aimed at preventing unauthorized access, disclosure, modification or unauthorized destruction of data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated.
In addition to the owner, in some cases, categories of persons involved in the organization of the site (administrative, marketing, commercial, legal, system administrators) or external subjects such as (such as third party technical service providers, postal couriers) may have access to the data , hosting providers, IT companies, communication agencies).

VIII – CHANGES TO THIS DOCUMENT

This document, published at the address: https://www.promoin.it/termsofservice.php
constitutes the privacy policy of this site.

It may be subject to changes or updates. In the case of significant changes and updates, these will be reported with specific notifications to users.
However, previous versions of the document will be available on this page.
The document was updated on 03/17/18 to comply with the relevant regulatory provisions and in particular with EU Regulation 2016/679.

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