Thank you for joining the Anubis Digital Platform (the “Platform”)
The purpose of this document (the "Information") is to inform the person interested party (the "Interested Party") about how his/her personal data as better described (the "Personal Data") will be collected and processed by the Controller as defined below in accordance with its obligations under Regulation (EU) 2016/679 of the Parliament European Parliament and of the Council of 27 April 2016 on the protection of individuals with with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR") and additional applicable data protection regulations.
This Policy may be amended at any time without obligation and at the sole Holder's sole discretion, in whole or in part, by updating it. In such case, the Data Controller will give notice by posting on the Site (as defined below), moment from which the aforementioned changes will become effective and binding for the Interested Party. To the extent permitted by law, if the Data Subject continues to use the Site and its its services after a modification has become effective, his or her access and/or use of the services shall be deemed to be an implied acceptance of the amended Policy and the obligations arising therefrom. The amended version supersedes all previous versions of the Policy.
This Notice has been prepared on the basis of the principle of transparency and all the elements required by the GDPR.The terms defined, if not contained in this Disclosure, refer to the General Terms and Conditions for the use of Anubi Digital services (the "Contract") and shall be shall be deemed to be directly incorporated herein.
The data controller is Anubi Digital S.r.l., based in Cuneo (CN) Via Carlo Pascal 7, 12100 (the "Titleholder"). The Holder's website is https://www.anubidigital.com (the "Site"). The data controller is Diego D'Aquilio and can be contacted at the e-mail address indicated in the paragraph 11 below.
The types of Personal Data related to the Data Subject collected by the Data Controller, including through the Site, are:
The Personal Data collected may be used for the fulfillment of contractual obligations, pre-contractual and any other obligation arising from a legal provision. Among the obligations contractual include the following activities:
The processing of Personal Data will be carried out using analog instruments, including computerized, with organizational and logical methods strictly related to the purposes indicated in previous art. 3. The Data Controller may, if necessary, entrust third parties with the processing of Personal Data Personal Data to third parties also by virtue of specific appointment as data processors by the Controller. By way of example, the following may be called upon to process Personal Data of the Data Subject the provider of the hosting service for the operation of the Site and/or the Platform as well as other service providers functional to the maintenance of the Site, the Platform and/or the provision of other services by the Data Controller.
In particular, for certain fulfillments required by the regulations set forth in Legislative Decree 231/2007. (Concerning the prevention of the use of the financial system for the purpose of money laundering criminal activities and the financing of terrorism) the company Arkès S.r.l. has been appointed as external treatment the company Arkès S.r.l., with registered office in Ripa di Porta Ticinese, 31, 20143, Milan (MI). The Personal Data being processed are: Personal and Contact Data as well as other Personal Data of the Data Subject (e.g., work activity performed and income data and assets, bank data, etc.).
For more information, the Data Subject may contact the Data Controller through the references indicated in paragraph 11 below.
The Data Controller is a company specializing in the creation of applications based on DLT (distributed ledger technologies) and that is, technologies based on distributed ledgers. Several applications make use of so-called public permissionless DLTs over which the Owner does not and cannot exercise any power of control, governance, or intervention. Although the Holder's applications do not involve, when properly used by the Data Subject, the recording of Personal Data readable on the DLTs (e.g., the name and surname of the Data Subject), some data relating to the transactions performed in the interest of the Data Subject may be subject to recording within the DLTs (e.g., the alphanumeric sequence identifying a transaction related cryptocurrency transfer). The nature of DLTs means that it is technically impossible to delete such data from the distributed ledger.
The processing of Personal Data is based on the following legal bases:
For further information on the legal basis of each processing, the Data Subject may send at any time an e-mail to the contact addresses indicated in paragraph 11 of the this Information Notice.
For the purposes referred to in Article 3, paragraphs (i) to (ix) of this Notice, the legal basis is the Company's obligation to fulfill the agreement between the Company and the Data Subject.
Personal Data will be stored at the operational headquarters of the Data Controller and at any other location where the parties involved, including any external data controllers, are located. There are no plans to transfer outside the European Union the Personal Data of the Data Subject except for the possible use of technological applications that have their own servers in non-EU countries. The Data Subject may at any time request further information on the methods of storage of Personal Data by sending an email to the addresses indicated in paragraph 11.
Personal Data will be kept for the period strictly necessary to fulfill the purposes for which it was collected. Personal Data will be retained for the entire duration of the contractual obligations undertaken by the Data Controller towards the Data Subject, the duration of the use of the Site by the Data Subject, for the time necessary for the fulfillment of the further purposes (e.g. the storage of the contact data of the Interested Party within the database of the Data Controller for promotional purposes related to the provision of services), for the time necessary to comply with applicable legal and regulatory obligations, as well as for own or third party defensive purposes.
If the processing of Personal Data is based on the consent of the Data Subject, the Personal Data Personal Data may be retained by the Data Controller until the consent is revoked. The Personal Data Personal Data may still be retained for a longer period if necessary to fulfill a legal obligation or by order of an authority. All Personal Data will be deleted or stored in a form that does not allow the identification of the Data Subject (anonymization) within 30 days after the end of the retention period.
The Personal Data collected will not be subject to any treatment and/or decision-making process automated, including profiling, that may produce legal effects for the Data Subject or that may significantly affect it. It should be noted that the Data Controller at any moment, at its own discretion, may carry out profiling activities by giving immediate communication, pursuant to art. 11, to the Data Subject in order to obtain his/her consent.
A Data Subject may exercise his or her rights at any time by notifying the Data Controller. In particular, the Data Subject may:
Personal Data may be made accessible, for the purposes mentioned above:
For any information regarding this Notice and/or the exercise of any of the rights or faculties indicated herein, the Interested Party may send an email to firstname.lastname@example.org.
In the event that the Interested Party wishes to file a complaint, he/she may do so by sending an appropriate communication to the following addresses: Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, PEC: email@example.com.
By accepting this policy, the Data Subject declares without reservation:
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Registered Office: Via Carlo Pascal, 7 - 12100 Cuneo (CN) - Italy - VAT: 03913000042
Turin Headquarters: I3P - Via Pier Carlo Boggio, 59 - 10138 Torino (TO) - Italy
Milan Headquarters: Fintech District - Via Filippo Sassetti, 32 - 20124 Milano (MI) - Italy