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THE MCDOLLAR ANSWER-BOOK TO ANY QUESTION YOU MAY HAVE:

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PRIVACY POLICY

MC DOLLAR

PRIVACY INFOMRATION PURSUANT TO ART.13 OF THE REGULATION (UE) 
N. 679/2016 (“GDPR”)

Welcome to McDollar's disclosure regarding privacy and the protection of your personal data. “McDollar” è un sito di proprietà di Schonhaut Advisory STP Srl via dalla Volta 19, 40131 Bologna (BO) – CF/P.IVA  03835581202, che ha in concessione d’uso a tempo indeterminato il relativo Marchio “McDollar – MS Expand your digital Transformation”, regolarmente registrato.

The regulation for the protection of European privacy (called GDPR, General Data protection Regulation) is considered by us a "constitutional legacy to build a better and more orderly society in a digital future", we consider it a positive thing that must be interpreted in the most transparent and honest to establish a relationship with you, which you are called "interested", based on trust and the real interest in relating. This is why this information is organized in two sections:

UNFORMAL

The first section tries to explain to you in the most practical, clear and understandable way what we do with your data and why we process them.

FORMAL

The second section details the information required legally in a formal and legally correct manner.

They are both important to have a complete picture of our privacy policy, based on your preferences and the time you have available we leave the choice of where to direct you to know our policies for the processing of your personal data that you have generously decided or are deciding to "lend us".

UNFORMAL SECTION

Having said all this, we are going to explain what data we request and process from the people interested in our services, or the type of processing we do of the data of the particular category that we call "Lead" and "Customers" and for what purpose. They are two different categories, to be considered together because the treatment of a "Lead" can evolve into a "Client" by adding new purposes but does not lose the conditions of "Lead", unless it is expressly requested. Obviously we also process data of other categories of people "Collaborators", "Suppliers", "Partners", but not through this information. If you are reading this information following your desire to leave us your data it is because you will be a "Lead" or a "Customer" for us.

As anticipated we process your data in order to interact with you, so we do not use them to resell them to third parties. Any initiative that you will receive as a result of the data you lend us will be managed by us and starts from the purpose of proposing to you potentially useful and interesting information or opportunities for your benefit. Then the choice is yours whether to ignore them or not. It is not our intention to "hammer" you with continuous advertisements, even if it is said to be "the soul of the trade". The truth is that we are a highly specialized and small-sized structure to guarantee the highest quality and competence in what we do, therefore we follow few customers and we don't care to chase anyone regardless. It is also true, however, that our Mission is "Expand you digital awareness" and that is why we try to spread the knowledge acquired in different ways to the widest possible audience among those interested, then focusing on collaborating with those who can really benefit from our services / products and in our way of working.

personal data

at the time of contact or registration request
name, surname, physical address, nationality, province and municipality of residence, landline and / or mobile telephone, fax, tax code, e-mail address (s), age, educational qualifications, profession, gender or other similar information. Not all of them will be requested every time, it depends on the moment
the reason for requesting these data is attributable to what is called purpose in the European regulation. The same data can in fact be used for different purposes and it is right that you "interested" can decide for what purpose you want your data that you lend us to be processed. Sometimes the purposes are mandatory and sometimes optional, it depends on the initiative you are signing up for. It does not want to be a stretch against you, it changes from case to case and we try to explain it to you as clearly as possible every time. For example, if you participate in a survey in order to receive specific information, before sending it we explain that your data will be recorded for marketing purposes (NB: marketing for us is not "advertising" but "communication") and for profiling purposes, because based on your questions we have created clusters that help us to better differentiate the information to be sent to you. We will notify you of this, but for that initiative these purposes are mandatory. Then we will ask you if you also accept other purposes that are not necessary at that time, in this case optional. It is useful for us to have the information of people potentially interested in the topics we deal with because it costs us enormously less to reach you with your data at our disposal than without through paid advertising and thus we optimize the fulfillment of our "Mission". because based on your questions we have created clusters that help us to better differentiate the information to be sent to you. We will notify you of this, but for that initiative these purposes are mandatory. Then we will ask you if you also accept other purposes that are not necessary at that time, in this case optional. It is useful for us to have the information of people potentially interested in the topics we deal with because it costs us enormously less to reach you with your data at our disposal than without through paid advertising and thus we optimize the fulfillment of our "Mission". because based on your questions we have created clusters that help us to better differentiate the information to be sent to you. We will notify you of this, but for that initiative these purposes are mandatory. Then we will ask you if you also accept other purposes that are not necessary at that time, in this case optional. It is useful for us to have the information of people potentially interested in the topics we deal with because it costs us enormously less to reach you with your data at our disposal than without through paid advertising and thus we optimize the fulfillment of our "Mission".
So what are the purposes of the data we process?

- Archiving/StatisticThese are purely archival purposes, they serve us to keep your data once you have given us your consent. Often this purpose is implicit if you authorize any other. How can we contact you if we don't save your data somewhere? We can use them internally for statistical purposes, or to evaluate in an aggregate sense how many people have come into contact with us over time, of a certain type etc.
- Marketingthese purposes are necessary to then get in touch with you through the data you provided, typically email or telephone, why do we also need other data in addition to these? To be able to communicate correctly or know more about yourself and therefore not to ask you unnecessary information or questions. In general, we ask from time to time only the information we need, integrating it gradually (for example, we do not ask for an address if this is useless at that moment), because we know that filling out endless forms is boring. If you ask to remove this purpose we will no longer be able to contact you!
- Profiling: this purpose is definitely not a bad thing! For us, this allows us to cluster people on the basis of their information provided to provide the information we believe to be most appropriate from case to case, without proposing, for example, an avalanche of useless emails which are then deleted for lack of interest. The classification rules we organize are all rules created by us humans and then automated to optimize our time. We don't always use it, and therefore sometimes this purpose is optional, but we always recommend accepting it so we can later insert the "Leads" already acquired in customized initiatives that require clustering, otherwise they remain outside the initiative
- Automatic Profiling: we use this purpose more rarely and often optional, compared to the initiatives we propose. If we want to exploit an artificial intelligence algorithm to generate the clusters we talked about in the profiling purpose, we can only use it for people who accept to be "classified" by automatic algorithms and not by the human being and can always be required to take it off. Keep in mind that the reason why we eventually use this profiling is to provide you "interested" with the things you are most "interested" in, we have no reason to annoy you. Maybe over time and on large numbers, a machine is able to better understand your possible interests that escapes us from a purely combinatorial evaluation (a combination of fixed attributes).
- AdministrativeThey are implicit purposes in the signing of a contract or service, we need to manage the relationship with you and are typically inherent in the terms of use of the contract in order to fulfill it according to law. This purpose relates to the "Leads" who become "Customers" and with whom a relationship is established that goes beyond communication.
These data may be requested:
- Through registration / registration forms to receive useful content or to be contacted later or to receive commercial information (both online and offline, on paper or in person). Registration always requires a confirmation from you of the data entered (this thing is called Double Optin, to prevent others from registering you without your knowledge), which takes place after sending a confirmation email.
- Through the exchange of business cards or direct contacts. In this case, however, you will always be sent an email asking you to confirm the offline registration so as not to generate misunderstandings.
The duration of the treatments depends on the purposes, each purpose has a deadline and as long as there is an active purpose for a specific reason, the data are kept and managed. Each time a purpose is signed and reaffirmed through a new explicit interaction by the interested party, the purpose "timer" is reset and starts all over again. Please note that if you are already our "Lead" and complete a new form, authorizing one less purpose than the last time, you are not revoking it but you are saying that you are not renewing the previous purpose (the previous authorization date applies), while for all those authorized, the timer is reset.
Alternatively, you can explicitly request this through the contacts we provide you in this statement. In particular, you can request to know if we manage your personal data and which ones (you need to provide an email for this, which represents our unique identifier and necessary to manage your data, which must be confirmed in order to process the personal data of the " interested"). We respond to these requests only if we find a match to the email provided in the question and send it to the email we found a match for. If we do not find a match, there will be no answer, because even a negative answer represents personal information that we are not authorized to provide.
I'll give you an example, let's say that Tizio-AT-mail.com sends an email to our contacts asking to know what data we manage of Caio-AT-gmail.com. We do not manage any data of Caio-AT-gmail.com, if we respond to Tizio-AT-gmail.com that we do not manage Caio-AT-gmail.com we would be processing CAIO's personal data without authorization by communicating to third parties (Tizio) that we do not know who CAIO is. If you do not receive a response to a legitimate request, or if you indicate an e-mail from you in the request, it is implied that we do not process your data. An automatic system would have sent them to you.
Obviously, the requested revocation will only take place when any legal obligations have lapsed. For example, if you ask to be canceled but you are a customer with a contract that is still active, we will remove all flags, except those necessary to fulfill the contract and administrative obligations (such as sending an invoice and keeping the contract data for tax reasons).
Below are the durations that we have deemed correct to fulfill the purposes of an activity such as McDollar's. If we no longer have interactions with you on a date after these terms, as the purposes expire and the data will be permanently deleted after all the purposes have expired:

- Archiving/Statistic: two months after all other purposes in which the interested party falls have lapsed. The data of the interested party could then be definitively anonymized, or saved as non-personal statistical information useful to the company never attributable to the specific natural person, neither directly nor indirectly (e.g. we keep track that a person with a certain age range has contacted us and has been interested in us for some time).
- Marketing: two years from the last "Opt in", acceptance of the purpose. No more e-mails will be sent after this purpose expires.
- Profiling: two years from the last "Opt in", acceptance of the purpose. The person will no longer be placed in any new cluster after this date. This purpose is strictly linked to that Marketing which is why, without different requests from the interested party, the timing follows.
- Automatic Profiling: two years from the last "Opt in", acceptance of the purpose. The person will no longer be inserted into any new cluster via automatic algorithms after this date. This purpose is strictly linked to that Marketing which is why, without different requests from the interested party, the timing follows.
-Administrative: 10 years, to fulfill the conservation of various kinds of law.
The data is stored only in digital form through tools and software services purely in the cloud. These third party services are necessary to manage a large amount of data and communications efficiently. We only turn to suppliers who adopt security measures for their transmission and storage appropriate to the type of data processed and their risk in case of loss. With each service provider there is a contract for the appointment of McDollar as data processor, which remains the exclusive owner, where it is guaranteed that the provider is compliant with the requirements expressed by the European regulation. Encryption, redundancy, confidentiality, Double authentication (as for banking provisions) are some of the measures that are adopted by these SW services, which can also be found in non-EU territories, but we turn to services that operate only in countries for which an agreement with Europe is in force for ensure compatibility in processing with our current regulations (e.g. United States). To perform our services efficiently using the best platforms for the benefit of the interested parties, we cannot guarantee that personal data, even if treated with the utmost care, scruple and attention, are kept only in European territory, even if this would be our preference.
The data may also transit on the personal devices of McDollar collaborators who are adequately trained on the rules of conduct to ensure data security and who are all appointed as data processors if external to the company Schonhaut Advisory STP Srl or alternatively are authorized to process. by written communication. Personal devices must meet normal safety requirements in terms of SW, care and storage. For transparency, we report the main tools / services that we can use to manage the personal data of "interested parties" and the reason:

- ActiveCampaign: Email Marketing
- LeadPages: Landing Pages
- WordPress/Woocommerce on Siteground: Website with ecommerce with purchasing features
- Hubspot: CRM
- 123FormBuilder: Form and survey to collect data
- Zapier: integrazione fra strumenti
- Microsoft Office 365: Email and calendar
- Calendly: Meeting scheduling
- Soluzione-Contabilità Portal: fiscal and administrative management
- Fattura24: invoincing
- Dropbox for Business: file management
- Thinkific: E-Learning Portal

In addition to these, it is right to mention for those concerned also the Social Networks from a business perspective: such as Facebook, Instagram, Linkedin, Youtube, Google Ads, Clubhouse, Twitter, Whatsapp. In this case, we do not provide any personal data of our ownership to these companies, but they may collect information on the tracking related to navigation on McDollar portals following the campaigns published on the social networks themselves. If these are then associated with personal information, it is the owner of the single social software to which the interested party has possibly given consent to the processing. In fact, social networks do not provide lists of personal data directly, It is always the will of the interested party to provide their data to McDollar explicitly and our collection takes place only upon registration for the purposes described. However, it may happen to receive comments or messages on social networks to which an answer is given, this does not fall within the management of a real personal data, but in a normal relationship of knowledge and exchange of opinions following a voluntary publication by the interested party of the own information, if any. We begin to manage your data when you confirm us with the appropriate form / email. but in a normal relationship of knowledge and exchange of opinions following a voluntary publication by the interested party of any information. We begin to manage your data when you confirm us with the appropriate form / email. but in a normal relationship of knowledge and exchange of opinions following a voluntary publication by the interested party of any information. We begin to manage your data when you confirm us with the appropriate form / email.

TELEMATIC TRAFFIC DATA

While browsing, there are various techniques of absolutely common and widespread practice to track user visits.

They are data, such as IP address of origin, Cookie, utm, Pixel etc. These data, which in themselves do not represent personal data, as they do not refer by themselves to a natural person, become so indirectly because they can be associated with the person when he or she gives consent to the processing of personal data.
The telematic traffic data can be used for the following purposes, but always according to the authorizations granted by the interested party:

- Archiving/Statistic: for example to know which communication channels are the best
- Marketing: for example it is useless to send an email to ask if you liked a content if this content has not been accessed by the interested party
- Profiling: information on the navigation paths can be used for example to understand if an interested party is interested in particular topics
- Automatic Profiling: information on the navigation paths can be used for example to understand if an interested party is interested in particular topics
The mechanisms are different and documented on the web and range from SEO to tracking.
The log data of these navigations are kept with the same timing of personal data and then in any case merged in a totally and irreversibly anonymous form.
The data is stored only in digital form through tools and software services purely in the cloud. These third party services are necessary to manage a large amount of data and communications efficiently. We only turn to suppliers who adopt security measures for their transmission and storage appropriate to the type of data processed and their risk in case of loss. With each service provider there is a contract for the appointment of McDollar as data processor, which remains the exclusive owner, where it is guaranteed that the provider is compliant with the requirements expressed by the European regulation. Encryption, redundancy, confidentiality, Double authentication (as for banking provisions) are some of the measures that are adopted by these SW services, which can also be found in non-EU territories, but we turn to services that operate only in countries for which an agreement with Europe is in force for ensure compatibility in processing with our current regulations (e.g. United States). To perform our services efficiently using the best platforms for the benefit of the interested parties, we cannot guarantee that personal data, even if treated with the utmost care, scruple and attention, are kept only in European territory, even if this would be our preference.
The data may also transit on the personal devices of McDollar collaborators who are adequately trained on the rules of conduct to ensure data security and who are all appointed as data processors if external to the company Schonhaut Advisory STP Srl or alternatively are authorized to process. by written communication. Personal devices must meet normal safety requirements in terms of SW, care and storage. For transparency, we report the main tools / services that we can use to manage the personal data of "interested parties" and the reason:

- ActiveCampaign: Email Marketing
- LeadPages: Landing Pages
- WordPress/Woocommerce on Siteground: Website with ecommerce with purchasing features
- Hubspot: CRM
- 123FormBuilder: Form and survey to collect data
- Zapier: integrazione fra strumenti
- Microsoft Office 365: Email and calendar
- Calendly: Meeting scheduling
- Soluzione-Contabilità Portal: fiscal and administrative management
- Fattura24: invoincing
- Dropbox for Business: file management
- Thinkific: E-Learning Portal

In addition to these, it is right to mention for those concerned also the Social Networks from a business perspective: such as Facebook, Instagram, Linkedin, Youtube, Google Ads, Clubhouse, Twitter, Whatsapp. In this case, we do not provide any personal data of our ownership to these companies, but they may collect information on the tracking related to navigation on McDollar portals following the campaigns published on the social networks themselves. If these are then associated with personal information, it is the owner of the single social software to which the interested party has possibly given consent to the processing. In fact, social networks do not provide lists of personal data directly, It is always the will of the interested party to provide their data to McDollar explicitly and our collection takes place only upon registration for the purposes described. However, it may happen to receive comments or messages on social networks to which an answer is given, this does not fall within the management of a real personal data, but in a normal relationship of knowledge and exchange of opinions following a voluntary publication by the interested party of the own information, if any. We begin to manage your data when you confirm us with the appropriate form / email. but in a normal relationship of knowledge and exchange of opinions following a voluntary publication by the interested party of any information. We begin to manage your data when you confirm us with the appropriate form / email. but in a normal relationship of knowledge and exchange of opinions following a voluntary publication by the interested party of any information. We begin to manage your data when you confirm us with the appropriate form / email.

FORMAL SECTION

 

I. INFORMATION

 

"McDollar" is a site owned by Schonhaut Advisory STP Srl Via dalla Volta 19, 40131 Bologna (BO) - CF / VAT number 03835581202, which protects the confidentiality of personal data and guarantees them the necessary protection from any event that may put them at risk of infringement. As required by the European Union Regulation n. 679/2016 ("GDPR"), and in particular to art. 13, below we provide the user ("Interested") with the information required by law relating to the processing of their personal data.

The information is provided only for McDollar 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 McDollar web pages, regardless of the purpose of the connection itself, according to Italian and European legislation.

The information may undergo changes due to the introduction of new rules in this regard, therefore the user is invited to periodically check this page.

If the user is under the age of 14, pursuant to Article 8, paragraph 1 of Regulation (EU) 2016/679, and to Art. 2 - Quinquies of Legislative Decree 196/2003, as amended by Legislative Decree 181/18, must legitimize his consent through the authorization of his parents or guardian.

 

II. CONTROLLER


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 the processing of personal data. It also deals with security profiles.

"Schonhaut Advisory STP Srl" based in Via dalla Volta 19, 40131 Bologna (BO), operates as the Data Controller and can be contacted at: gdpr@mcdollar.com

 

III. DPO - DATA PROTECTION OFFICER


The person responsible for the protection of personal data is the person designated by the Data Controller and / or by the data processor on the basis of Article 37 of Regulation (EU), 2016/679.
The Data Controller has appointed a Data Protection Officer - DPO who can be contacted for any information and request:

Eng. Marco Schonhaut, Via dalla Volta 19, 40131 Bologna (BO)
e-mail:gdpr@mcdollar.com

 

IV. PROCESSOR


The data processor is the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller.

The data controller has appointed various data processors in compliance with the rules pursuant to article 28 of regulation (EU) no. 2016/679, for the computerized management of data through SW services (cloud services) and for administrative / accounting management in particular. Upon justified request, it is possible to provide a list of processors at the time of the request and related documentation for appointments and compliance with the law.

 

V. METHODS AND NATURE OF DATA PROCESSING

 

The processing of data generated by the use of "McDollar" takes place mainly from the headquarters of the data controller but also on the move.

McDollar collects and / or receives the following personal information concerning the Data Subject:

 

1. Telematic traffic data such as:

- internet protocol (IP) address
- type of browser and device parameters used to connect to the site
- name of the internet service provider (ISP)
- date and time of visit
- web page of origin of the visitor (referral) and exit
- possibly the number of clicks

The aforementioned information is processed in an automated form and collected in order to verify the correct functioning of the site, and for security reasons. This information will be treated on the basis of the legitimate interests of the data controller. For security purposes (spam filters, firewalls, virus detection), the automatically recorded data could be used, in accordance with the laws in force on the subject, in order to block attempts to damage the site itself or damage other users, or in any case activities. harmful or 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, such information will be treated on the basis of the legitimate interests of the data controller.

 

2. Personal data at the time of contact or registration request such as:

- Name, surname
- physical address, nationality, province and municipality of residence
- landline and / or mobile telephone, fax
- tax code
- e-mail address (s)
- age, gender
- educational qualifications, profession.

"McDollar" does not require the interested party to provide so-called "particular" data, or, according to the provisions of the GDPR (Article 9), personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs , or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or sexual life or sexual orientation of the person. In the event that the service requested from "McDollar" requires the processing of such data, the interested party will receive specific information in advance and will be asked to give specific consent.

 

3. If the site or pages connected to the site on social networks allow the insertion of comments, this information is made public by the interested party voluntarily. By inserting a comment or other information, the user expressly accepts the privacy policy, and in particular agrees that the contents entered are freely disseminated to third parties.

 

VI. PURPOSE AND LEGAL BASIS (Article 13, 1st paragraph GDPR)

 

The data are used by the Data Controller to follow up the request for the purchase of products / services, manage and execute the contact requests forwarded by the interested party, provide assistance, fulfill the legal and regulatory obligations to which the Data Controller is required in relation to the activity exercised. . Under no circumstances does "Schonhaut Advisory STP Srl" resell the personal data of the interested party to third parties or use them for undeclared purposes.

In particular, the data of the interested party will be processed for the following purposes:

 

a) Archiving and Statistics: The registry registration and requests for contact and / or information material are recorded and stored.
The processing of the personal data of the interested party takes place to carry out the preliminary activities and consequent to the request for registration, the management of requests for information and contact and / or sending information material, as well as for the fulfillment of any other obligation resulting.
Legal basis of these treatments is the fulfillment of the services inherent to the request for registration, information and contact and / or sending information material and compliance with legal obligations. Statistical use of such data is done in a totally aggregated form and by anonymizing the data with the aim of providing an increasingly efficient and better service in a general sense. For this exercise, the explicit consent of the interested party is not required.

 

b) AdministrativeThe management of the contractual relationship
Il trattamento dei dati personali dell’Interessato avviene per dar corso alle attività preliminari e conseguenti all’acquisto di un prodotto/servizio, la gestione del relativo ordine, l’erogazione del Servizio stesso e/o la produzione e/o la spedizione del Prodotto acquistato, la relativa fatturazione e la gestione del pagamento, la trattazione dei reclami e/o delle segnalazioni al servizio di assistenza e l’erogazione dell’assistenza stessa, la prevenzione delle frodi nonché l’adempimento di ogni altro obbligo derivante dal contratto.
Legal basis di tali trattamenti è l’adempimento delle prestazioni inerenti il rapporto contrattuale ed il rispetto di obblighi di legge.

 

c) Marketing: Le attività promozionali su Servizi/Prodotti
The processing of the personal data of the interested party takes place to carry out the preliminary activities and consequent to the purchase of a product / service, the management of the related order, the provision of the Service itself and / or the production and / or shipment of the purchased Product, the related invoicing and payment management, the handling of complaints and / or reports to the assistance service and the provision of the assistance itself, the prevention of fraud as well as the fulfillment of any other obligation deriving from the contract. The legal basis of these treatments is the fulfillment of the services inherent to the contractual relationship and compliance with legal obligations.
– e-mail;
- mobile messages;
and can be carried out:
- if the interested party has not revoked his consent for the use of the data;
- if, in the event that the processing takes place through contact with a telephone operator, the interested party is not registered in the register of oppositions referred to in DPR n. 178/2010;

Legal basis of these treatments is the consent given by the interested party prior to the treatment itself, which can be revoked by the interested party freely and at any time.

 

d) Profiling

The personal data of the interested party may also be processed for profiling purposes (such as analysis of the transmitted data and the selected Services / Products, proposing advertising messages and / or commercial proposals in line with the choices made by the users themselves) exclusively in the event that the interested party has provided explicit and informed consent.
Legal basis of these treatments is the consent given by the interested party prior to the treatment itself, which can be revoked by the interested party freely and at any time.

 

e) Automatic Profiling

The personal data of the interested party may also be processed for profiling purposes using automatic tools based on artificial intelligence algorithms only if the interested party has provided explicit and informed consent.
Legal basis of these treatments is the consent given by the interested party prior to the treatment itself, which can be revoked by the interested party freely and at any time.

 

f) IT security
The Data Controller, in line with the provisions of Recital 49 of the GDPR, processes, also through its suppliers (third parties and / or recipients), the personal data of the interested party relating to traffic to a strictly necessary and proportionate extent. to guarantee network and information security, i.e. the ability of a network or information system to withstand, at a given level of security, unforeseen events or illegal or malicious acts that compromise availability, authenticity, integrity and confidentiality of personal data stored or transmitted.
The Data Controller will promptly inform the Data Subjects, if there is a particular risk of violation of their data, without prejudice to the obligations deriving from the provisions of art. 33 of the GDPR relating to notifications of personal data breaches.
Legal basis of these treatments is compliance with legal obligations and the legitimate interest of the Data Controller to carry out treatments related to the protection of the site and the security of the offices and systems of the "Schonhaut Advisory STP Srl" site

 

g) the prevention of fraud (recital 47 and art.22 GDPR)
- in the case of online purchases, the personal data of the interested party, with the exception of particular (Art 9 GDPR) or judicial (Art 10 GDPR) data will be processed to allow controls for the purpose of monitoring and preventing fraudulent payments, by software systems that carry out an automated check and prior to the negotiation of Services / Products;
- passing these checks with a negative result will make it impossible to carry out the transaction; the interested party may in any case express their opinion, obtain an explanation or contest the decision by giving reasons for their reasons to the Customer Assistance service or to the contact gdpr@mcdollar.com;
- personal data collected for anti-fraud purposes only, unlike the data necessary for the correct execution of the requested service, will be immediately deleted at the end of the control phases.

 

h) the protection of minors
The Services / Products offered by the Data Controller are reserved for subjects legally able, on the basis of the relevant national legislation, to conclude contractual obligations.
The Data Controller, in order to prevent illegitimate access to its services, implements preventive measures to protect its legitimate interest, such as checking the tax code and / or other checks, when necessary for specific Services / Products, the correctness of the data identification of identity documents issued by the competent authorities.

 

VII. DATA TRANSFERS TO THIRD COUNTRIES (art.44-49 GDPR)

 

The Data Controller does not transfer your personal data to third countries in non-EU countries where the GDPR is not applied or where there are no agreements that guarantee policies compatible with the European GDPR regulation. If this happens, explicit prior consent will be required.

 

VIII – COOKIES

 

VIII.1 - Type of Cookies

 

1. The McDollar site uses cookies to make the user's browsing experience easier and more intuitive: cookies are small text strings used to store some information that may relate to the user, his preferences or the access device to Internet (computer, tablet or mobile phone) and are mainly used to adapt the operation of the site to the user's expectations, offering a more personalized browsing experience and storing the choices made previously.
2. A cookie consists of a reduced 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.
3. 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
For further updated information on the cookies used, please refer to the dedicated page, automatically generated by the hosting provider of the site itself:
https://www.mcdollar.com/cookie-policy

 

VIII.2 - Technical cookies

 

1. There are numerous technologies used to store information on the user's computer, which are then collected by the sites. Among these, the best known and most used is that of HTML cookies. 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.
2. 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 deletion of cookies by changing the settings of his internet browser. This deactivation may slow down or prevent access to some parts of the site.
3. The use of technical cookies allows the safe and efficient use of the site.
4. The cookies that are inserted in the browser and retransmitted through Google Analytics or through the blogger statistics service or similar are technical only if used for the purpose of optimizing the site directly by the owner of the site, who can collect information in aggregate form on the number of users and how they visit the site. Under these conditions, the same rules apply to analytics cookies, in terms of information and consent, provided for technical cookies
5. 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 in to each page visited and the permanent ones that remain active on the PC until upon expiry or cancellation by the user.
6. Session cookies may be installed in order to allow access and stay in the reserved area of ​​the portal as an authenticated user.
7. They are not stored permanently but only for the duration of the navigation until the browser is closed and disappear when the browser 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.

 

VIII.3 - Third party cookies

 

1. In relation to the origin we distinguish the cookies sent to the browser directly from the site you are visiting and those of third parties sent to your computer from other sites and not from the one you are visiting.
2. Permanent cookies are often third party cookies.
3. Most third-party cookies consist of tracking cookies used to identify online behavior, understand interests and then customize advertising proposals for use
4. Third-party analytical cookies may be installed. They are sent from the domains of the aforementioned third parties external to the site
5. Third party analytical cookies are used to detect information on user behavior on McDollar. The survey 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, in order to propose advertising messages in line with the choices made by the users themselves.
6. The use of these cookies is governed by the rules established by the third parties themselves, therefore, users are invited to read the privacy policies and instructions for managing or disabling the cookies published on the relative web pages.

 

VIII.4 - Profiling cookies

 

1. Profiling cookies are those that create profiles relating to the user and are used in order to send advertising messages in line with the preferences expressed by the user while surfing the net.
2. When these types of cookies are used, the user must give explicit consent for this purpose.
3. Article 22 of Regulation (EU) 2016/679 and Article 122 of the Data Protection Code will apply.

 

VIII.5 - Support in configuring your browser

 

1. The user can also manage cookies through the settings of his browser. However, deleting the cookies from the browser could remove the preferences set for the site.
2. For further information and support, you can also visit the specific help page of the web browser you are using:

– Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
– Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences
– Safari: http://www.apple.com/legal/privacy/it/
– Chrome: https://support.google.com/accounts/answer/61416?hl=it
– Opera: http://www.opera.com/help/tutorials/security/cookies/

 


IX. USER RIGHTS

 

1. Art. 13, c. 2 of Regulation (EU) 2016/679 lists the user's rights
2. The McDollar site therefore intends to inform the user about the existence of the user's rights, based on the following articles of Regulation (EU) 2016/679:

a) Based on art. 15, of the right of the interested party to ask the owner for access to personal data, based on art. 16 the possibility of rectifying the data provided, on the basis of article 18, the possibility of integrating or limiting the treatment concerning him, or to oppose, for legitimate reasons, their treatment based on art. 21, in addition to the right to data portability based on art. 20 Regulation (EU);
b) the right to request cancellation based on Article 17, transformation into anonymous form or blocking of data processed in violation of the law, including those which do not need to be kept for the purposes for which the data have been collected or subsequently processed.
c) 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.

3. Requests can be addressed to the data controller, without formalities or, alternatively, using the model provided by the Guarantor for the Protection of Personal Data, or by sending an email to: gdpr@mcdollar.com
4. If the processing is based on art. 6, paragraph 1, lett. a) - express consent to use - or on art. 9, paragraph 2 lett. a) - express consent to the use of genetic, biometric, health-related data, revealing religious or philosophical beliefs or trade union membership, revealing racial or ethnic origin, political opinions - the user has the right to revoke consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.
5. Likewise, in case of 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 responsible for monitoring the processing in the Italian State.
6. For a more detailed examination of your rights, see articles 15-22 of Regulation (EU) 2016/679.

 

X. Details on the right to object

 

1. When Personal Data are processed in the public interest, in the exercise of public authority vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons connected to their particular situation.
Users are reminded that, if their Data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.
2. How to exercise your rights
To exercise the User's rights, Users can send a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month

 

XI. Further information on the treatment

 

1. Defense in court
The User's Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this site or related Services by the User.
The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.
2. Specific information
At the request of the User, in addition to the information contained in this privacy policy, this site may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.
3. System logs and maintenance
For needs related to operation and maintenance, this site and any third party services used by it may collect system logs, i.e. files that record the interactions and which may also contain Personal Data, such as the User IP address
4. Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
5. Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this site as well as, if technically and legally feasible, by sending a notification to Users through one of the extremes contact number held by the Data Controller. Please therefore consult this page regularly, referring to the date of the last modification indicated at the bottom.
If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

 

XII. Definitions and legal references

 

Personal Data (or Data)
Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage Data
This is information collected automatically through this site (including from third-party applications integrated into this site), including: the IP addresses or domain names of the computers used by the User connecting to this site, the addresses in URI notation (Uniform Resource Identifier), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application,with particular reference to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment of the User.

User
The individual who uses this site who, unless otherwise specified, coincides with the Data Subject

Data Subject
The natural person to whom the Personal Data refers.

Data Processor
The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller
The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the measures security relating to the operation and use of this site. The Data Controller, unless otherwise specified, is the owner of this site.

This Site
The hardware or software tool through which the Personal Data of Users are collected and processed.

Service
The Service provided by this site as defined in the relative terms (if any) on this site / application.

European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

Cookie
Small piece of data stored in the User's device.

Legal references
This privacy statement is drafted on the basis of multiple legislative systems, including articles. 13 and 14 of Regulation (EU) 2016/679. Unless otherwise specified, this privacy statement applies exclusively to this site

 

XIII. DISCLAIMER AND COPYRIGHT

 

COPYRIGHT
The content of this site, including all information, data, documents and databases, is protected under the laws on copyright. In particular, the rights of reproduction, adaptation, translation and total or partial storage, by any means, are reserved for all countries.

DISCLAIMER
The opinions and interpretations expressed in the documents prepared by Schonhaut Advisory STP Srl published on this site - unless otherwise indicated - are the result of independent studies conducted by the company itself, updated at the time of their date. The material and contents presented on the site have been carefully screened and analyzed and have been elaborated with due care, nevertheless errors, inaccuracies and omissions are always possible. The company therefore declines any responsibility for errors and omissions that may be present on the site. Schonhaut Advisory STP Srl also declines all responsibility for any type of use made by third parties of the material contained on the site. The site contains pages, information and documents, as well as links to websites managed by third parties. Schonhaut Advisory STP Srl has no control over such contents, nor can it affect their structure and, therefore, does not guarantee nor is responsible for the materials and information contained therein, and, in particular, for the correctness, quality, accuracy and legality of the same. Schonhaut Advisory STP Srl declines all responsibility for any inaccuracies of a material nature contained in the site, as well as for any damage deriving from the malfunction of the site due to technical causes.

 

XIV. CHANGES TO THIS DOCUMENT

 

1. This document, which constitutes the privacy policy of this site, is published at:
www.mcdollar.com/privacy-policy
2. 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.
3. The previous versions of the document will still be available on this page:
https://www.mcdollar.com/privacy-history 

4. The document was updated on 14/02/2021 to comply with the relevant regulatory provisions, and in particular in compliance with Regulation (EU) 2016/679.

McDollar

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