Privacy Policy
Who we are and what we do with your personal data
Last updated: January 2023
We provide you with this privacy policy in accordance with Regulation (EU) 2016/679 (hereinafter referred to as "GDPR") to summarize what we do with your personal data when you use our services and/or access our content and how you can exercise your rights at any time as recognized by law (hereinafter also referred to as "data subject").
We are committed to processing your personal data in accordance with GDPR, Legislative Decree 196/2003 and subsequent amendments (hereinafter referred to as "Privacy Code"), relevant measures and guidelines of data protection authorities and national and European judicial authorities, as well as applicable national and European legislation.
We have done our best to provide you with all the necessary information while requesting the least possible reading time and allowing you to deepen, where appropriate, some aspects through a series of notes. We invite you to carefully read this privacy policy regarding the processing of your personal data carried out by Givuma LLC. through its websites and/or applications (hereinafter referred to as "Sites") and to contact us for any clarification or to suggest how to improve this document to make it clearer, more transparent and more accessible.
Specific information is also provided in the individual sections dedicated to particular initiatives and/or services: please refer to the specific indications provided there in order to identify the characteristics of the treatments carried out. Such information is to be considered as completed - where expressly referred to - by this privacy policy regarding the processing of personal data of users of the Sites. In case of conflict, the information provided in the specific information dedicated to particular initiatives and/or services prevail.
Finally, we remind you that any processing of personal data carried out by the owners of other websites, even if reachable through links/plug-ins present on the Sites, will be subject to the privacy policies of such third parties.
1. Who processes your personal data and how to contact us
The data controller for your personal data is Givuma LLC (hereinafter referred to as "Givuma", the "Controller" or "We").
Any requests regarding the processing of your personal data can be sent to the Controller by mail at the following address: Givuma LLC, 3 Hanover Sq Apt 8E, 10004 – New York (NY) USA, or using the following email address: info@terredamare.it.
Our company has appointed a Data Protection Officer ("DPO") whom you can contact at the following address: info@terredamare.it.
2. What personal data concerning you do we process and where do we collect it from
For the purposes indicated in the following section 3, the Controller may process common personal data concerning you. For example, the Controller may process personal data such as identifying information, contact information, financial information necessary for the purchase of products and/or services on the Sites and/or through vocal order, login credentials to restricted areas of the Sites (i.e. user ID/email and password to log in), data related to your preferences and consumption habits, socio-demographic data, personal data contained in comments published by you on the Sites, images, data relating to your browsing (for more information on this type of processing, please refer to our cookie policy), further categories of personal data, as requested from time to time depending on the type of service you intend to use. Please refer specifically to the information provided in the sections dedicated to particular initiatives and/or services to verify whether different categories of personal data are processed.
Givuma does not intentionally collect special categories of personal data (i.e. those capable of revealing your ethnic origin, political opinions, religious or philosophical beliefs, or union membership, as well as your genetic data, biometric data intended to uniquely identify you, data relating to your health or sex life or sexual orientation), as well as data relating to criminal convictions and offenses, and invites you not to provide such data and/or information from which they could be inferred (e.g. within comments published by you on the Sites).
Givuma may collect your personal data at the time of your registration or during the course of the relationship with Givuma: directly from you (e.g. to allow your registration to one of the Websites and/or purchase of products and/or services from the Websites, during contact with our Customer Service or by writing to the contact addresses on the Websites, in relation to comments you publish on the Websites); from companies of the Group or, possibly, from our business partners to whom you have provided them, for example, to participate in specific initiatives organized or promoted by these same subjects (e.g. events, loyalty programs, initiatives, contests or prize operations), to access our services (e.g. Facebook log-in). Such data may be communicated to us by the subjects indicated in accordance with their respective privacy notices.
Notwithstanding the above, it is noted that Givuma may collect personal data of third parties, in the following cases: (i) if one of our members intends to gift a subscription to one of our publications and/or services, and for this purpose communicates to us the necessary data to allow the registration of such subject; (ii) in the event that the user communicates to Givuma the identification and contact details of the subject who will benefit from any benefits (e.g. the "bring a friend" initiative); (iii) if our users publish personal data of third parties (e.g. in comments or in connection with our initiatives). Please note that you are required, in cases where you provide personal data of third parties, to provide this notice (and the specific notice(s) specifically associated with the relevant initiative) to such subjects.
In any case, Givuma will provide suitable information to these subjects, on the occasion of the first contact with them. In such cases, this notice assumes the value of art. 14 GDPR, providing interested parties with relevant information regarding the processing of their personal data.
Furthermore, we invite you not to provide us with personal data that is not strictly necessary.
3. For what purposes do we process your personal data
Below we illustrate the purposes for which we process and/or may process your personal data.
A. Use of the content and services offered through the Websites
We will process your Personal Data in order to fulfill your request to create an account - as indicated in the General Terms and Conditions available [here] - to access all Givuma Network Websites and use the services offered that require registration (e.g. the newsletter service, initiatives, contests or prize operations), purchase our paid services (also by phone using vocal order), use the services offered through the Websites that do not require registration or subscription purchase, as well as to personalize the content offered through the Websites.
With regard to the aforementioned activities, your Personal Data will also be processed for all administrative, financial and/or legal operations related to them.
B. Customer Service
We will process your personal data to manage assistance requests, including those related to the activation or deactivation of a purchased subscription, that you submit to our customer service, through any of the available platforms (e.g. phone, fax, chat, email) ("Customer Service"), as well as to fulfill your request for information and/or clarifications, following your communication using the contact addresses on the Websites.
C. Compliance with legal obligations
We will process your personal data in order to comply with legal obligations to which we are subject and any other obligation deriving from orders of the competent authorities.
D. Corporate transactions and defense of rights
We may also process your personal data for the completion of any corporate transactions (e.g. due diligence, merger, split, acquisition, transfer of assets and/or business units, etc.) and to ascertain, exercise or defend a right or interest of the Data Controller or of a third party (including other companies of the Group) in court and/or out of court.
E. Verification of user satisfaction and service functionality
We will process your personal data in order to verify the proper functioning of our services, measure the level of satisfaction of our users and, with specific reference to our Customer Service, improve the quality of customer care processes and more effectively orient the training of personnel assigned to such service. In order to know your level of satisfaction and improve our services, we may also send you customer satisfaction questionnaires to the email address you provided and/or make them available on our Websites and/or through other means, in which you may participate on an optional basis. We also inform you that in order to allow us to pursue our legitimate interest in verifying the quality of the service provided to our customers, telephone calls received by the Customer Service may be recorded.
F. Soft Spam
Limited to our products and/or services similar to those you already use or have used, we may send you commercial communications using the email address you provided at the time of use and/or purchase of one of the services referred to in the previous letter A. You may exercise your right to object to receiving such commercial communications at any time.
For more information regarding your right to object to processing based on legitimate interest, please refer to the following section 8.
G. Profiling
With your consent, we will process your personal data, also through tracking technologies such as cookies, to carry out activities of analysis and processing of information about you aimed at defining a profile of your preferences, habits, consumption choices and/or browsing experiences. Such profiling activities may also be conducted using tools provided by third parties, such as social networks (e.g. Facebook) or third-party advertising service providers (e.g. Google), and adopting, where possible, security measures such as "hashing" (which involves associating your personal data, e.g. email, with strings of numbers and letters, effectively anonymizing your data). To this end, we may also associate the personal data acquired through tracking technologies such as cookies (if you have given your consent) and/or the personal data provided by you as part of our specific initiatives and/or initiatives of our third-party partners (and, in the latter case, in any case in compliance with the respective privacy notice), with those that we acquire by virtue of your registration on one of the Websites or by virtue of their use. To pursue this purpose of processing, Givuma may also use anonymous information, not referring to any data subject, present in public databases and information systems (e.g. census data).
H. Commercial communications
With your consent, we will process your personal data to inform you, also through automated contact tools (email, SMS, push notifications and/or other online placements, also on social networks, phone with or without operator), about our commercial initiatives, including offers dedicated to you even following deactivation of your subscription, to conduct market research and to send advertising material, as well as to send you, through the indicated tools, communications regarding commercial initiatives of other companies of the Group and/or our commercial partners.
I. Communication of your personal data to third parties for commercial purposes
With your consent, we will process your personal data to communicate them to other companies within the Givuma Group and/or our commercial partners operating in the following sectors, so that they can use them for commercial and/or promotional purposes: telecommunications, fixed and mobile telephony, companies in the publishing, print, new media, and television (pay-TV) sectors, companies operating in the e-commerce of products and services, companies operating in the utilities sector - gas, electricity, water, photovoltaic, and water purification, companies operating in the tourism sector - tour operators, travel agencies and transport companies - and leisure, companies dealing with professional and/or school education, advertising and marketing agencies, media centers, market research and contact centers, companies operating in the production and/or sale of consumer goods: food and beverages, non-food grocery, cosmetics and health, clothing, semi-durable goods, NGOs and non-profit organizations, foundations, companies operating in the automotive sector, companies operating in the financial, banking, and insurance sectors, and sports companies.
J. Statistical analysts
We will process your personal data for the production of aggregate and anonymous statistics in order to evaluate and improve our services. In any case, the personal data processed for statistical purposes will not be used to make decisions or take measures directed at individual data subjects, nor for the pursuit of other purposes.
4. What legal basis do we use to process your personal data
Below we indicate the legal basis for processing for each of the purposes indicated in the previous section.
Performance of a contract or pre-contractual measures (Art. 6, para. 1, letter b) GDPR)
The Personal Data collected for the purposes set out in letters A and B will be processed as necessary to perform a contract of which you are a party and/or pre-contractual measures taken at your request. Such processing is necessary and therefore failure to provide personal data, when mandatory, will not allow us to provide the requested service.
Compliance with a legal obligation (Art. 6, para. 1, letter c) GDPR)
The personal data collected for the purpose set out in letter C will be processed to comply with a legal obligation to which Givuma is subject. Their provision is therefore necessary and your refusal will not allow us to provide the requested service.
Legitimate interest (Art. 6, para. 1, letter f) GDPR)
The Personal Data collected for the purposes set out in letters D, E, F and J, will be processed on the basis of Givuma's or third party's legitimate interest. The provision of your data for these purposes is not necessary for the provision of the services requested by you; however, failure to provide them or your objection to the processing will not allow us to evaluate the functioning of our services and to improve the satisfaction of our customers for the same, as well as in the cases provided for in letter F, to send you commercial communications about products and/or services similar to those subject to your purchase and/or use. For more information on your right to object, please refer to the following section 8. In addition, for more information on the legitimate interests pursued and the related balancing tests conducted by us, you can contact us at the contact details provided in this information.
Consent (Art. 6, Par. 1, Lett. a) GDPR)
The data collected for the purposes outlined in letters G, H, and I will be processed only with your freely given, specific, informed, and unambiguous consent. Providing your personal data for these purposes is not necessary for the provision of the services requested by you; however, failure to provide consent - or revocation of previously given consent - will prevent you from receiving communications, including potentially personalized ones, on commercial initiatives from Givuma and/or other companies in the Group and/or our commercial partners. With regard to purpose H only, we remind you that, in case of failure to provide or revoke consent, you can still receive commercial communications relating to products and/or services similar to those you have already purchased and/or subscribed to, for which processing is based on a legitimate interest of the Data Controller, against which you may always exercise your right to object.
For more information on your right to revoke consent at any time or on your right to object to processing based on legitimate interest, we invite you to consult the following Section 8.
We remind you that Givuma does not intentionally collect special categories of personal data about you. If such data are voluntarily provided by you (for example, in comments you publish on the Sites or in photos depicting your image that you send to the editorial offices for publication), they will be processed solely to allow you to take advantage of the services outlined in Section 3.A. and in consideration of the fact that such personal data have been made manifestly public by you (Art. 9, Par. 2, Lett. e) of the GDPR).
5. How we process your personal data and for how long
We process your personal data in electronic and paper form, ensuring their protection from the design phase and by default, and by adopting technical and organizational security measures aimed at guaranteeing a level of security appropriate to the risk.
Your personal data will be processed for the time strictly necessary to achieve the purposes for which they are collected and will be kept for different periods of time, depending on the purpose pursued. At the end of the indicated retention period, your personal data will be deleted or anonymized, unless it is necessary to keep them for longer for different purposes for which the data were legitimately collected (e.g. provision of the requested service and/or to comply with a legal obligation, an order from an Authority, or to defend our rights). For more information on the retention periods identified by Givuma for each of the purposes outlined in the previous Section 3, please click here.
6. Who we may disclose your personal data to and why
For the purposes outlined above, we may disclose your personal data to the following categories of recipients:
Third-party individuals and/or companies who provide services related and/or instrumental to the activities carried out by Givuma and described in the previous section 3 (e.g. companies that carry out activities in the publishing, marketing and advertising sector, including providers of social networking or other advertising platforms, companies that provide IT, storage and/or other administrative, accounting or legal services to Givuma, and operators who carry out call center activities on our behalf);
Group companies that need it for administrative, accounting or legal reasons;
With your consent, Group companies and/or our commercial partners as autonomous data controllers, for marketing purposes;
Legal and/or tax consultants and/or companies involved in possible merger, spin-off, acquisition, transfer of assets and/or business units or other extraordinary operations;
Independent authorities, law enforcement agencies or the judiciary for their institutional purposes within the limits provided for by law.
With regard to the personal data communicated to them, the aforementioned recipients may act, depending on the circumstances, as data processors, based on a specific agreement for the processing of personal data with Givuma, or as autonomous data controllers, based on their own privacy policy (in which case the communication of personal data will be limited to what is necessary to achieve the purposes of the processing referred to in the previous section 3, and will be carried out on the same legal bases as those indicated in section 4). A detailed and up-to-date list of these recipients and their privacy qualifications can be requested from the Data Controller.
Your personal data may also be accessed by personnel appointed by the Data Controller, who have been specifically instructed on the methods and purposes of the processing.
7. Transfer of personal data outside the European Economic Area
If necessary for the purposes indicated in the previous section 3 of this notice, your personal data may be transferred outside the European Economic Area (hereinafter "EEA").
Whenever your personal data needs to be transferred outside the EEA, particularly to countries that do not benefit from a decision of adequacy by the European Commission, we will adopt one of the safeguards provided for by the current legislation on personal data protection. For instance, we will sign the Standard Contractual Clauses adopted by the European Commission, ensuring that they are up to date, and adopt any further technical, organizational and/or contractual measures suitable to ensure a level of protection for your personal data that is adequate and, in any case, essentially equivalent to that guaranteed within the EEA. Following the judgment of the Court of Justice of the European Union of 16 July 2020 in Case C-311/18, Givuma carries out specific assessments concerning the additional safeguards to be adopted with regard to third countries that are not recipients of an adequacy decision by the European Commission, in order to prevent interference by local public authorities that could jeopardize the level of essential equivalence of protection of the data transferred there, compared to the level enjoyed under European law.
The list of countries outside the EEA to which we may transfer your personal data is available upon request, by contacting us at the contact details provided in this notice.
8. What are your rights and how can you exercise them
In relation to the processing of your personal data carried out by Givuma, you can ask us, at any time, to access, rectify and delete your personal data, as well as to limit its processing. You can also object to processing based on our legitimate interest and/or exercise the right to data portability concerning your personal data. Finally, you can revoke any consent you may have given at any time.
If you believe that the processing of your personal data violates the principles set forth by the current legislation on the protection of personal data, you can file a complaint with the judicial authority or with the supervisory authority for the protection of personal data in the member state where you habitually reside, work or where the alleged violation occurred. The competent authority in Italy is the Authority for the Protection of Personal Data.
The Data Controller reserves the right to limit or delay the exercise of these rights, within the limits established by applicable laws, in compliance with Article 23 of the GDPR and Articles 2-undecies and 2-duodecies of the Privacy Code.
To exercise these rights, make reports or request clarifications on the processing of your personal data, you can send an email to privacy@gedidigital.it or write to Givuma S.r.l., at the registered office in Via Ernesto Lugaro n. 15, 10126 - Turin or at the administrative office in Via Cristoforo Colombo n. 90, 00147 - Rome, inserting "Attention: DPO" in the address.
We also remind you that if you do not wish to receive commercial phone calls, you have the possibility to exercise the right to object to advertising calls, by registering with the Public Register of Oppositions, according to the methods made available by the manager of the Register based on the current applicable legislation.
9. Personal data processed by the publisher in the exercise of journalistic activity – Right to be forgotten
We inform you that this information concerns exclusively the processing of personal data that you have provided or will provide to Givuma - possibly also by purchasing or subscribing to our products and/or services or participating in our promotions and/or offers - and those that, if any, Givuma will acquire during the course of this relationship and/or further relationships between you and us.
If you wish, instead, to exercise the right to be forgotten with reference to your personal data that may be contained in articles of the newspaper and processed by the publisher in the exercise of journalistic activity, we remind you that the data controller is the publisher itself, as indicated in the management section of the relevant website, to which you can address, for the exercise of this right under Article 17 of the GDPR, writing to the contact details indicated in the "Management" or "Editorial staff" (or similar) section of the same website.
10. How we may change this policy
If it becomes necessary due to any regulatory changes or as a result of the evolution of some of our services or the technologies used to provide them, we may need to update this document.
We will take care to inform you of any significant changes.
However, we invite you to periodically visit this page to check that nothing has changed.
In no case, however, will we expand the purposes for which we process your data without first notifying you of such a need and, if necessary, obtaining your consent.