This information is provided pursuant to Article 14 of the EU Regulation 2016/679 (GDPR) in order to provide Data Subjects, recipients of the Controller’s commercial communications, with the following information.
Data Protection Officer (DPO) and contact details.
At this time, the Owner has not appointed a DPO/DPO
Categories of data processed and sources of origin
The data processed by the Controller comes from the Apollo.io platform, owned by the Zenleads, Inc. company, which has collected it in the manner and under the terms set forth in its privacy policy, which can be found at the following link https://www.apollo.io/privacy-policy/. Specifically, the processed data has become the property of the Data Controller based on an existing service provision relationship between Zenleads Inc. and the Data Controller.
The data processed are common personal data, such as but not limited to: a) master data (first name, last name); b) contact data (phone number, e-mail address) and the like.
The data processed could also be general browsing data from the navigation of the user who has landed on the Apollo.io platform and who may have brought with them information about previous browsing of other sites, including in particular cookies and other similar technologies.
Purpose of processing
Personal data, as described above, will be processed in the manner and form prescribed by the GDPR, as part of the data controller’s own activities.
Specifically, the processing of personal data is aimed at:
- Carrying out marketing activities (e.g. marketing campaigns, sending newsletters; promotional and advertising activities related to the services performed by the Owner), carried out on any online channel and in particular via e-mail
- Performance of other purposes ancillary or related or consequential to those indicated above and falling within the activities of the Holder;
- Carrying out profiling activities of the Data Subject, in order to address personalized offers and promotions to him/her based on his/her behavior and interests.
Legal basis for processing
For all personal data, the processing of personal data is based on the following condition of lawfulness (legal basis):
- Art. 6 par. 1(a) GDPR = consent. The processing of personal data carried out by the Data Controller is based on the consent acquired upstream from the Apollo.io platform and for the management of all personal data under purposes No. 1, No. 2 and No. 3;
- in Art. 6 para. 1 (f) GDPR = legitimate interest, provided that the interests or fundamental rights and freedoms of the data subject do not prevail for all processing included in information society services, as well as for information purposes of the Data Controller or the possible implementation of direct marketing operations pursuant to Recital 47 of the GDPR.
Treatment modes
The aforementioned data are processed exclusively in electronic format.
Recipients of any communications and data transfers
The data may be disclosed to companies, professionals and other consultants, as well as to third-party companies that have a business partnership relationship with the Controller, both intra-EU and extra-EU (in the latter case, it will be exclusively to entities for which an adequacy decision is in force or adequate safeguards are in place including Standard Contractual Clauses or consent has been collected or additional exemptions are provided under Article 49 GDPR, in accordance with the dictates of the Schrems II Judgment of the Court of Justice of July 16, 2020).
In any case, the data may be disclosed to data processors and persons authorized to process the data, as well as to any additional autonomous Data Controllers, again for the same or related purposes. Recipients include in particular: the Owner’s operators as authorized persons for processing, its Data Processors and related authorized persons for related purposes, e.g. of a managerial or fiscal nature, Google Ireland Ltd for Google Sheets for the management of commercial contact i and related services therein. No generalized communication of data will be carried out for further purposes, and no dissemination of personal data will take place.
Storage period
The data voluntarily given by the Data Subject will be kept until the consent given by the Data Subject is revoked.
Rights of the Data Subject
The Data Subject has the right of access, rectification, erasure (forgetting), restriction, receipt of notification in case of rectification, erasure or restriction, portability, objection, and not to be subjected to a decision based solely on automated processing, including profiling, that produces legal effects concerning him or her or that significantly affects him or her in a similar way, pursuant to Articles 15 to 22 of the GDPR.
These rights may be exercised in the forms and terms set forth in Article 12 GDPR, by written notice sent to the Controller by e-mail to the above e-mail address.
The Holder will render an appropriate response as soon as possible and in any case within the period of 1 month from the receipt of the request, except in cases of extension or justified refusal under Article 12 GDPR.
Right to withdraw any consent given
Where the processing is based on consent, the Data Subject may revoke it at any time by sending an e-mail to the Data Controller’s e-mail address mentioned above, or by using the appropriate unsubscribe link at the bottom of the newsletter.
Right to lodge a complaint
The Data Subject has the right to lodge a complaint pursuant to Articles 77 et seq. of the GDPR with a supervisory authority, which for the Italian state is identified in the Garante per la protezione dei dati personali.
The forms, methods and time limits for bringing complaints actions are provided for and governed by current national legislation, for Italy by special regulations of the Guarantor.
The complaint is without prejudice to any other administrative or jurisdictional recourse; for jurisdictional actions for damages, in Italy the action is brought before the competent court.
Data controller and contact details
The data controller is CdWeb Srl, C.F 06016170968 with Headquarters in Milan, cap 20134 , email info@cdwebagency.com
