Data Protection Policy
WHITE LANDS SRL Data Protection Policy
Last updated: 19/02/2020
DATA PROTECTION POLICY
WHITE LANDS SRL respects your privacy, and is deeply committed to protecting your personal data and empowering you to control how it is used.
This Data Protection Policy (hereafter “Policy”) applies to residents of EU states and certain other customers in states whose governments adopt Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data “General Data Protection Regulation” (“GDPR”). This Policy is intended to ensure that Customer Personal Data (defined as “any information relating to an identified or identifiable natural person”) is collected, maintained and used in accordance with the GPDR and associated data protection and privacy laws.
This Policy describes what kinds of Personal Data WHITE LANDS SRL will collect from our European Customers, and how WHITE LANDS SRL maintains and uses our Customers’ Personal Data in connection with the services we provide to them.
This Policy is hereby expressly incorporated into our User Agreements governing the provision of Services by WHITE LANDS SRL to our Customers residing in states subject to the GDPR (our “European Customers”). This Policy supplements our Contract, and is effective as of 25 May 2018.
Who is responsible for the processing of Customers’ Personal Data?
WHITE LANDS SRL is the data controller in the sense of the applicable data protection regulations:
WHITE LANDS SRL
Via Andrea Doria, 19
10123, Turin (Italy)
Personal Data WHITE LANDS SRL may collect from its Customers.
WHITE LANDS SRL collects Personal Data as described in the Contract, in particular from application forms, contact forms, and/or other interactions with Customer.
Customer should be aware that application fields are mandatory fields, because WHITE LANDS SRL needs this information to comply with statutory, legal or contractual requirements, internal procedures or to respond to Customer requests.
Fields: WHITE LANDS SRL may request include: Email, Mobile Phone number, Name, Home address, Date of birth and other. If Customer contacts WHITE LANDS SRL will keep a record of that correspondence for the legally required retention period.
Personal Data that Customers provide to WHITE LANDS SRL should not include any of the following data types, and Customers hereby expressly warrant that they will not provide any of the following:
- racial or ethnic origin;
- political opinions;
- religious or philosophical beliefs;
- trade union membership;
- genetic data;
- biometric data;
- private health data concerning a Customer;
- data concerning a natural person's sex life or sexual orientation.
WHITE LANDS SRL may use Customer Personal Data to send direct marketing to our Customers via e-mail only when Customer has given express prior consent in the relevant contact form. Customer may at any time withdraw approval to receive marketing communications by expressly withdrawing consent via mail at INFO@WHITELANDS.IT or using the newsletter unsubscribe functionality
WHITE LANDS SRL will not rely solely on automated Customer onboarding processes or transaction monitoring, including profiling.
How does WHITE LANDS SRL use Customer Personal Data?
Customer Personal Data is collected and handled by WHITE LANDS SRL for the following purposes:
to deliver WHITE LANDS SRL services (including to respond to Customer requests or questions, to investigate or respond to potential incidents and complaints);
to comply with applicable statutory, legal and regulatory obligations (including but not WHITE LANDS SRL to the fight against money laundering and terrorist financing).
Lawfulness of our Personal Data processing.
WHITE LANDS SRL use of Customer Personal Data as described herein is permitted by applicable data protection law, in particular, Article 6(1) of GDPR, on the basis that it is:
necessary for the performance of a contract to which the Customer is a party;
subject to Customer’s consent, which WHITE LANDS SRL shall obtain from time to time (for instance, when a Customer opts in (ticking the box) to receive marketing communications via email);
in certain cases as necessary to meet WHITE LANDS SRL statutory, legal or regulatory obligations;
in certain cases as necessary to safeguard WHITE LANDS SRL legitimate interests in pursuing the purposes set out above, WHITE LANDS SRL in scope such that such interests in each case do not obviate Customer privacy interests.
Sharing Personal Data with third parties.
WHITE LANDS SRL do not disclose Customer Personal Data to third parties.
WHITE LANDS SRL will retain Customer Personal Data for as long as (1) necessary for the respective purpose, (2) necessary to deliver services and carry out WHITE LANDS SRL business relationship with Customer in accordance with the Contract, (3) Customer has consented to, and/or (4) required by applicable retention laws.
Although WHITE LANDS SRL will do its best to protect Customer Personal Data, every Customer should be aware and is hereby informed that the transmission of information via the internet is not inherently secure. CRIMINAL HACKERS AND OTHER BAD ACTORS WILL ATTEMPT TO STEAL YOUR DATA AND DIGITAL ASSETS! WHITE LANDS SRL cannot guarantee the security of Customer Personal Data transmitted to WHITE LANDS SRL or any third party; for this reason, ANY TRANSMISSION IS AT CUSTOMER’S OWN RISK.
WHITE LANDS SRL will use industry standard (or better) technical and organizational security measures safeguard against unauthorized access, change, transmission or deletion of Customer Personal Data.
Customer rights: How can a Customer access, object, rectify, and delete its Personal Data?
Under applicable data protection laws, Customer has the following rights:
Right to access and obtain a copy of Customer Personal Data: Customer is entitled to request confirmation if and when WHITE LANDS SRL processes your Customer Personal Data. Customer may have access to Personal Data and learn details upon request about how it is maintained and used. In some cases, Customer can ask WHITE LANDS SRL to provide Customer with an electronic copy of Personal Data.
Right to object to marketing: if Customer expressly objects to WHITE LANDS SRL’s use of Customer Data for marketing purposes, WHITE LANDS SRL will put Customer personal contact information (name, address, telephone number, fax number, e-mail address) on a specific list to ensure that Customer no longer receives this material. The Customer Data will be maintained and used for non-marketing purposes unless and until Customer expressly withdraws the objection to marketing in writing.
Right to rectify Personal Data: If evidence can be provided that Personal Data WHITE LANDS SRL holds about Customer is inaccurate, or needs to be updated, Customer can update this data via the WHITE LANDS SRL wallet interface.
Right to be forgotten/Personal data erasure: In certain circumstances, Customers have the right to have their personal data deleted. Customer may make such a request at any time in writing and WHITE LANDS SRL will evaluate if Customer’s request should be granted.
However, this right is subject to overriding legal rights or obligations; WHITE LANDS SRL may be legally required to retain European Customer data, including in cases of suspicious transactions as to which WHITE LANDS SRL is legally obligated to retain all relevant records, or to conduct internal investigations, or to use European Customer data (while safeguarding a specific identity) for purposes of general data security. For situations where, in accordance with the law, WHITE LANDS SRL determines that a Customer’s data deletion request must be granted, WHITE LANDS SRL will do so without undue delay. To exercise this deletion right, Customer must submit a request to WHITE LANDS SRL support service and thereafter respond to any legitimate inquiries regarding the deletion request.
To the extent WHITE LANDS SRL’s retention or use of European Customer Personal Data is based on Customer consent, the Customer also has the right to withdraw consent at any time. Withdrawal of Customer consent pursuant to this Policy will not affect the lawfulness of any processing based on Customer consent before the receipt of such withdrawal.
WHITE LANDS SRL will only send marketing communications via email and catalogue. Customer may opt out of any further marketing communications using the un-subscribe right at any time by contacting WHITE LANDS SRL at INFO@WHITELANDS.IT and providing the following information: Customer name, email address, the marketing communications to unsubscribe.
Otherwise, the un-subscribe option will be always available in every marketing communications in the bottom panel of the emails
Changes to this Policy.
The terms of this Policy may be amended from time to time in accordance with WHITE LANDS SRL's internal rules and/or change in law or regulation. WHITE LANDS SRL shall publish any material changes to this Policy either on its Website or contacting Customer using other communication channels
Questions, comments and requests regarding this Policy are welcomed and should be addressed to WHITE LANDS SRL at the following e-mail address: INFO@WHITELANDS.IT