This policy defines the criteria and procedures used for the processing of personal data provided at the time of registration to Dontshare and content published on Dontshare by registered Users.
Given that the services and products described in this document may also be accessed and made available by the company Dontashare srl with legal address Via Ampère 61/A – 20131 Milano, Italy – VAT no: IT 09455710963, registration number with the Register of Companies of the Chamber of Commerce of Milano REA 2092326, owner of the Platform and the personal information provided by the Users of Dontshare.
Intent and purpose of data use
This policy defines the criteria and procedures used for the processing of personal data provided at the time of registration to Dontshare and content published on Dontshare by registered Users. The policy also relates to public Users, that is, those who visit the website www.dontshare.it without registering.
By processing of personal data under Art. 4. paragraph a) of Legislative Decree 196/2003, we mean any operation or set of operations concerning the collection, recording, organisation, storage, consultation, processing, selection, extraction, editing, comparison, use, blocking, communication, dissemination, erasure and destruction of personal data.
In this section, Dontshare therefore proposes to illustrate the ways in which they collect and use the information provided by the User when registering and creating a profile on Dontshare, as well as any other information that Dontshare acquires through the use of the service by all Users, both registered and public (public Users meaning those who have not yet registered their profile and who therefore cannot use the functions of the Platform).
The information provided by the User, necessary for the registration of a profile on Dontshare may be used by Dontshare to interact with the User, e.g. to allow the User to receive notifications by e-mail about the Dontshare service.
All Users are encouraged to carefully read the Policy set forth below. In order to complete registration to Dontshare and use the services offered to its subscribers, the User is required to give their consent to the processing of personal data, pursuant to Legislative Decree no. 196/2003.
Consent is given by the User by accessing the website and creating an account. It is important that the User carefully read this document and the document relating to the Terms and Conditions of Use of the Dontshare Service.
After completion of the registration procedure for Dontshare, and once the procedures relating to the purchase of the service have been carried out, the User will be able to access the services provided for registered Users and start entering their content in their own dedicated area. The inclusion of such content is voluntary and is done at the sole discretion of the User according to their own personal choice and under their own responsibility. In this context, it must be duly taken into account that, by publishing content on the Platform, it is possible, even unknowingly, to provide and disclose further personal information.
Any publication of content, regardless of whether it is entered in the encrypted part of the Platform (and any personal data resulting or emerging from it, even indirectly) is in any case a free personal choice of the User, made totally voluntarily and for which Dontshare takes no responsibility whatsoever, such a choice being made under the personal and exclusive responsibility of the User.
Upon registration, Dontshare prompts the User for personal information and identification. Regarding payment for the service, Dontshare points out that the necessary data are not collected or processed by the Platform because the User will use secure payment systems that are external to the Platform. Therefore all data relating to the User’s credit card or debit card, IBAN code and any other data relating to payment (except personal data) are not collected by Dontshare.
Within the service, Dontshare also collects information on services used by the User, whether registered and public (unregistered), and on they way the service itself is used. Data is collected from any type of device used.
This information includes:
-Information on the device used : we may collect device-specific information used by the User to connect to the Dontshare service (e.g. hardware model, type and version of operating system, browser type and language setting).
-Information on logs: the log-file is a file in which the transactions the User performs during the Dontshare session are registered.
During the use of our services by Users, we automatically collect and store certain pieces of information in the server logs. This information includes:
- Data regarding the way the service is used, such as search queries, date and time of inquiries and of the URLs referred to by the Dontshare service, etc.
- IP address
- Information on the events of the device, hardware settings, browser type and language;
NB Unless cookies are accepted the Dontshare Platform cannot be used.
As part of the Dontshare service, cookies are used to manage the session of each User, or to perform automatic authentication and to store the usage preferences expressed by Users who have not accessed the service, such as the interface language, search preferences, etc..
Use of collected data
Dontshare uses the data collected to allow Users to register with the Dontshare.it website, to offer its services, to monitor use of the Platform, to test the efficiency of the security procedures, to check compliance with the Terms and Conditions of Use of the Service, to improve the services and to make them more functional, always with the primary goal of protecting and respecting Users’ privacy.
The information gathered by Dontshare is used to enable full use of the features and services offered.
Dontshare also gives the User the opportunity to interact by sending messages and/or requests for clarification on a number of fundamental issues such as, for example, reporting abuse or requesting clarification of privacy concerns, etc.
If the User decides to contact Dontshare, the Company may store the contents of the communications sent by the User – if this is useful and/or necessary to provide a better service – and in this case, Dontshare may also use the User’s e-mail address to send responses and/or other service information.
Registered and public Users
The Dontshare service is open to everyone with no requirement to register. However, registration by the User, the creation of an account and payment for the service are required in order to take full advantage of all the features offered.
Users who choose not to register (public Users) can use only the navigation functions on the public pages of the Platform, for example About Us, How it works, Contacts, and so on.
Any User who decides to register for the Dontshare service must fill out the registration form, were they must indicate, in addition to their personal data, their email address and phone number and the email address of the VIP (delegated by the User to access the Dontshare Life Deposit Box). Concurrently with the completion of the registration form the User enters data about their credit card and proceeds with the payment that enables them to use the Platform.
The email address used to register, being an item of the User’s personal information, will never be sold to third parties for marketing or commercial purposes. The same applies to the number provided for SMS messages.
Data processing methods used by Dontshare
Pursuant to Art. 11 of Legislative Decree no. 196/2003, the personal data of the User will be processed lawfully and correctly and will be stored in a form which permits identification of the User for a period of time no longer than necessary for the purposes for which they were collected and subsequently processed.
The processing of Users’ personal data will be done by electronic means and in the manner prescribed by Art. 34 of Legislative Decree no. 196/2003.
Personal data and identification data of the registered User will not be processed for any other purpose except those set forth within this policy and always in full compliance with legal obligations.
Additional data collected by Dontshare, relating to both registered and non-registered Users, are processed to meet legal requirements, and to improve the Dontshare service and the User’s experience.
In compliance with the provisions of Art. 31 of Legislative Decree no. 196/2003 “Code concerning the protection of personal data” and further legislation governing the matter, Dontshare processes all data collected in full compliance with security and confidentiality requirements. Dontshare adopts all appropriate security measures to minimise the risk of destruction or accidental loss of data held, unauthorised access, and processing that is not allowed or not consistent with the aforementioned purposes. Dontshare further states that data will be entered in a protected database in full compliance with privacy laws.
In any case, pursuant to Art. 7 of Legislative Decree no. 196/03, each individual User is granted the right to obtain information about the collection of data and the way data processing is performed, the right to request the updating or integration of the data, the right to object to processing of data concerning the User and the ability to exercise the rights of access, rectification and deletion of the personal data provided.
To exercise these rights, the interested party may send their requests by writing an email to the Privacy Officer at the address firstname.lastname@example.org.
In compliance with the provisions of Art. 8 of Legislative Decree no. 196/2003, Dontshare will provide a prompt reply to the User by e-mail.
Under Art. 10 of Legislative Decree no. 196/2003, if, as a result of the aforementioned request, the existence of data regarding the applicant is not confirmed, the Data Controller may request payment of a fee not exceeding the costs actually incurred for the search carried out at the request of the User.
We remind that Users that they may view, check and edit all the data they have supplied at any time, by logging into their profile on www.dontshare.it.
Dontshare does not provide personal information to third parties, but may supply it when such information is reasonably required to:
- comply with requests of the competent authorities in compliance with any applicable law or regulation, legal action or the like;
- apply the current Terms and Conditions of Use of Dontshare including checks relating to potential violations;
- detect, prevent or otherwise handle fraudulent activity or security or technical issues;
- protect the rights, property or security of Dontshare and the registered Users, as required or permitted by law.
Other persons authorised to process data
Pursuant to Articles 4 paragraphs f) and g), 13 paragraph f), 28 and 29 of Legislative Decree no. 196/2003, the persons authorised to process the personal data of Dontshare Users are:
1) the Data Controller, who is responsible for decisions regarding the aims and methods of processing personal data and the tools used, including the security profile;
2) those responsible for the processing of data, who are authorised by the Data Controller.
The Data Controller is the company Dontshare srl, registered office at Via Ampère 61/A – 20131 Milano, Italy – P.Iva IT09455710963
in the person of its Director, Mr.Mauro Mercatanti.
Conservation of data collected by Dontshare
The data requested of the User by Dontshare during registration will be conserved for the entire duration of the relationship between the User and Dontshare and until such time as the relationship is terminated.
The User is further informed that Dontshare has the legal obligation to keep copies of some data for a certain period of time, in accordance with the provisions of national laws regarding the matter (Legislative Decree no. 109/2008 which amended Legislative Decree no. 196/2003).
The conservation of other data acquired by Dontshare according to the service provided to the User and/or to non-registered Users, will be conserved by Dontshare in an aggregated and anonymous form.