Welcome to T.consulT’s Privacy Policy

 

    We’re T.consulT SRL registered in Mantova Corso Vittorio Emanuele II, 101, Italy (“T.consulT”) and welcome to our privacy policy. This policy sets out how we handle your personal information if you’re a T.consulT user or visitor to our Sites. It applies across T.consulT Sites, and Novaevo  Hosted (the “Sites”).

    When we say ‘we’, ‘us’ or ‘T.consulT’ it’s because that’s who we are and we own and run the Sites.

    If we say ‘policy’ we’re talking about this privacy policy. If we say ‘user terms’ we’re talking about the rules for using each of the Sites. The rules vary by product and each product makes them separately available and seeks consent to them separately to this policy.

 

The type of personal information we collect

 

    We collect certain personal information about visitors and users of our Sites.

    The most common types of information we collect include things like: user-names, member names, email addresses, IP addresses, other contact details, survey responses, blogs, photos, support queries, forum comments, content you direct us to make available on our Sites (such as item descriptions) and web analytics data. We will also collect personal information from job applications (such as, your CV, the application form itself, cover letter and interview notes).

 

How we collect personal information

 

    We collect personal information directly when you provide it to us, or through other people when you use services associated with the Sites.

    We collect your personal information when you provide it to us when you complete membership registration and buy or provide items or services on our Sites,  email list, submit feedback or send us a communication.

 

Personal information we collect about you from others

 

    Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular:

        financial and/or transaction details from payment providers located in the UK  and Europe in order to process a transaction;

        other third party sources/ and or partners from Europe,  whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data, and combine it with information we have about you. We also receive information about you and your activities on and off the T.consulT platform through partnerships, or about your experiences and interactions from our partner ad networks. We also receive information about you as a rights holder from our third party authors.

 

How we use personal information

 

    We will use your personal information:

        To fulfil a contract, or take steps linked to a contract.

        Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:

            operating the Sites;

            providing you with services described on the Sites;

            responding to support tickets, and helping facilitate the resolution of any issue;

            updating you with operational news and information about our Sites and services e.g. to notify you about changes to our Sites, website disruptions or security updates;

            carrying out technical analysis to determine how to improve the Sites and services we provide;

            monitoring activity on the Sites, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Sites;

            managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites or via mail or, asking for your feedback or whether you want to participate in a survey;

            managing our legal and operational affairs (including, managing risks relating to content and fraud matters);

            training T.consulT staff about how to best serve our user community;

            improving our products and services.

            providing general administrative and performance functions and activities; and

            processing your job application to T.consulT.

        Where you give us consent:

            providing you with marketing information about products and services which we feel may interest you; and

            customizing our services and applications,.

        For purposes which are required by law.

        For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.

 

When we disclose your personal information

 

    We will disclose personal information to the following recipients:

        companies that are in the T.consulT group which are located in UK and Europe;

        authors of any items or services made available to you, so they can facilitate support and license validation, who maybe located in any of the countries our products are available in;

        subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: hosting providers which are located UK; technical and customer support services which are located in UK and Europe; recruitment agencies which are located in Italy; Noting that our subcontractors and services providers may also transfer and access such information from  other countries in which they have operations.

        our professional advisers (lawyers, accountants, financial advisers etc.) which are located in Italy and UK;

        regulators and government authorities in connection with our compliance procedures and obligations;

        a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;

        a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;

        a third party, in order to enforce or defend our rights, or to address financial or reputational risks;

        a rights holder in relation to an allegation of intellectual property  infringement or any other infringement; and

        other recipients where we are authorised or required by law to do so.

 

Where we transfer and/or store your personal information

 

    We are based in Italy so your data will be processed in Italy and the UK. Some of the recipients we have described in section 10 above, and to whom we disclose your personal information, are based outside Italy and the UK. We do this on the basis of your consent to this policy. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

 

How we keep your personal information secure

 

    We store personal information on secure servers that are managed by us, and occasionally hard copy files that are kept in a secure location in Italy. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.

 

How you can access your personal information

 

    You can access some of the personal information that we collect about you by send a mail to privacy-consult.it..

 

Information you make public or give to others

 

    If you make your personal information available to other people, we can’t control or accept responsibility for the way they will use or manage that data. There are lots of ways that you can find yourself providing information to other people, like when you post a request for assistance directly via email. Before making your information publicly available or giving your information to anyone else, think carefully.

 

How long we keep your personal information

 

    We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations. If you no longer want us to use your personal information or to provide you with the T.consulT services, you can request that we erase your personal information. Please note that if you request the erasure of your personal information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

 

When we need to update this policy

 

    We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.

    When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.

 

How you can contact us

 

    If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact our privacy champion in writing at T.consulT, Via Caduti del lavoro, 1, 46010, Curtatone (MN), Italy,  or privacy@t-consult.it.

    We’re really glad you made it to the end of the privacy policy, because knowing this stuff is the best way to understand how your personal information is used and how to best manage it!

If you’re a user or visitor in the European Economic Area these rights apply to you:

    For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.

 

How you can access your personal information

 

    You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.

    These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.

    Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.

    If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.

 

Both personal information and personal data have the same meaning in the context of this Privacy Policy.

 

T.consulT Privacy Policy v3, effective date 25 May 2018