Privacy Policy

General information

Welcome to our braccialettiaua.com website (the Website).

At Braccialetti Aua, your privacy and the security of your personal data are really important. That is why we collect and handle your personal data with the utmost care and take appropriate measures to keep them safe.

Below you will find information on how Braccialetti Aua processes your personal data in relation to your navigation of brainpull.com and use of the offered services. For detailed information on how Braccialetti Aua manages your personal data, please read this Privacy Policy in full.

Regarding the use of cookies, please read the "Cookie Policy", which contains detailed information about the use of cookies in the terms of our services and during the use of the site.

Certain services may be subject to different legal terms, in which case we will provide you with all the relevant information from time to time.

The data controller

The data controller of personal data is Gruppo Horus Srl, via Roma, 3, 70044, Polignano a Mare (BA), VAT REG. No. 07873700723, Tax ID 07873700723 (Braccialetti Aua).

Data processor

Gruppo Horus Srl, via Roma, 3, 70044, Polignano a Mare (BA), VAT REG. No. 07873700723, TAX ID. 07873700723, was appointed as the Personal Data Processor.

Please contact the Data Processor at any time by sending an email to privacy@brainpull.com stating "privacy" in the subject line for any clarification, question or requirement related to your privacy and the processing of your personal data.

Collected personal data

The categories of personal data that Braccialetti Aua collects and processes when you browse on Braccialetti Aua are as follows:
we collect the personal data you provide when you fill in one of the contact forms on braccialettiaua.com; 
we collect the personal data you provide when you request a service offered on braccialettiaua.com; 
we collect the personal data you provide when you subscribe to our newsletter service; 
we collect your CV when you send it to us to be considered for a position. The collection will concern only common data, therefore the candidate will not have to provide so-called special data, as defined by Article 9 of Regulation (EU) 2016/679 or sensitive data, as defined by Legislative Decree 196/2003 (e.g. health status). In the latter case, the data subject is invited to express his/her explicit written consent to the processing of data, by writing the following at the bottom of the curriculum vitae, or in the cover letter: ""Pursuant to Legislative Decree no. 196 of 2003 I agree that Gruppo Horus srl may process my personal data, including any sensitive data, for the purposes and in the manner specified in the policy"" or other equivalent wording; 
we collect information about your navigation on brainpull.com, such as the pages you visit and how you interact with the specific pages, and save this information on our servers; in case you provide Braccialetti Aua with personal data of third parties, for example in cases where you decide to request information on behalf of a friend, after notification, Braccialetti Aua will make sure to deliver to the third party the privacy policy at the time of the first communication. Please note that the use of personal data of third parties is subject to the data protection regulations.
We inform you that Braccialetti Aua does not process any personal data relating to minors. If you access brainpull.com and use the services offered by Braccialetti Aua you declare that you are of legal age

Purpose for use personal data

Braccialetti Aua collects and processes your personal data for the following purposes:

subject to your prior express consent, handling of your requests to Braccialetti Aua, using the personal data you provide to fulfil your requests for information and assistance;
subject to your prior express consent, providing the services offered on brainpull.com. To this end, Braccialetti Aua needs to collect, in relation to each service and its characteristics, the personal data required to carry out the service you have requested; 
job application. If you send us your CV in order to be taken in consideration for a position, with your express consent, we will use the information included in your CV solely for that purpose. Your CV will be kept for a maximum term of twelve months, after which it will be deleted: if you wish, you can, of course, send a new, updated version to us; 
with your express consent, we may use the personal data you have provided us with for commercial communications about our products and services in order to keep you up to date with news, our offers, promotions and other communications about the company and its related brands; 
with your express consent, we may use your contact details for the purposes of carrying out statistical research, opinion polls and market research in order to improve our services, our products, our activities and our relationship with our users;
we process personal data relating to your browsing, such as the pages you visit and how you interact with the individual page, i.e. traffic, to the extent strictly necessary and proportionate to ensure network and information security; 
with your express consent, we may use automated or non-automated profiling mechanisms on the personal data collected, including behavioural analysis for promotional and advertising purposes; the creation of lists for promotional purposes, e.g. for the use and activation of personalised audiences and audiences deemed to be similar, User-ID profiling tools from Google Analytics and similar activities on Facebook, Google and other appropriately selected third parties offering suitable guarantees of compliance with the rules on the processing of personal data; the creation of lists for commercial communication; the creation of lists for sending newsletters; the elaboration of profiles for the provision of services targeted and customised to the customer's needs; the analysis of your browsing and consumption habits as part of the use of your Braccialetti Aua profile, in order to customize your experience on our Site. Such profiling mechanisms do not form the basis of decisions which have legal effects and do not affect the concerned individuals in any significant way.
In connection with all of the above activities, we will process your personal data mainly by means of computerised and electronic tools, in full compliance with the relevant legislation.

Legal grounds for processing

We process your personal data only if one of the conditions laid down in the applicable legislation is met, and specifically according to the following legal grounds:

for our legitimate interest.
Some of your personal data may be processed to the extent strictly necessary and proportionate to ensure network and information security.
With regard to these data, which we are obliged to know in order to comply with the statutory obligations, EU regulations and national legislation, or provisions issued by Authorities empowered by law and by supervisory and control bodies, any failure to provide them on your part will make it impossible to establish or continue the relationship, to the extent that such data are necessary for the performance thereof.

on the basis of your consent.
We will only carry out the following processing operations provided that you have granted your express consent to us:

fulfilling your requests for information and requests for assistance to Braccialetti Aua 
performing of one of the services offered on Braccialetti Aua that you have requested; 
if you send us your CV, in order to be taken in consideration for an application for a job position with Braccialetti Aua; 
carrying out promotional and commercial activities, including receiving newsletters; 
carrying out statistical research, opinion polls and market research; 
activation and use of automated, or non-automated, profiling mechanisms, which do not base decisions that have legal effects and do not significantly affect the individuals involved.
Providing us with your personal data for these activities is on a fully discretionary basis. You are free to provide us with your data for these purposes or not, but without them it will not be possible for Braccialetti Aua to carry out the activities described in points i., ii., iii., iv., v., vi.
Who processes the data 
Your personal data will be processed by the internal staff of Braccialetti Aua that is specifically trained and authorised to process them.

I tuoi dati personali saranno inoltre eventualmente trasmessi a soggetti terzi di cui ci avvaliamo per fornire i nostri servizi o svolgere le nostre attività; tali soggetti sono stati adeguatamente selezionati e offrono idonea garanzia del rispetto delle norme in materia di trattamento di dati personali. Questi soggetti sono stati designati da Braccialetti Aua, svolgono la loro attività secondo le istruzioni impartite da Braccialetti Aua e sotto il suo controllo.

I soggetti terzi in questione appartengono alle seguenti categorie: operatori bancari, internet provider, società specializzate in servizi informatici e telematici; corrieri; società che svolgono attività di marketing; società specializzate in ricerche di mercato e nell'elaborazione dati.

Your personal data may also be forwarded to third parties that we employ to provide our services or carry out our activities. These third parties have been properly selected and offer sufficient guarantees of compliance with the rules on the processing of personal data. These entities and individuals were appointed by Braccialetti Aua, carry out their activities according to the instructions given by Braccialetti Aua and under its control.

Web push notification

Depending on the device you are browsing from, you may receive, with your consent, push notifications about our company, its products or services.

To deactivate notifications, based on the employed platform and/or browser, please follow the following steps:

Desktop: Right-click on the notification > disable notifications from braccialettiaua.com 
Mobile: Access the notification centre > Site parameters > Notifications > Block notifications from braccialettiaua.com 
Common browsers:
Chrome: Settings > Show Advanced Settings > Privacy - Content Settings > Notifications - Manage Exceptions > Enter brainpull.com and select "Block" 
Firefox: Options > Contents > Notifications - Choose > brainpull.com - "Block" 
Safari: Preferences > Notifications > From here set the selector to "Reject" 
Transfer of data outside the EU 
Some of the third parties listed in the "Who processes your data" section above may be based in countries outside the European Union that nevertheless offer an adequate level of data protection, as established by specific decisions of the European Commission https://www.garanteprivacy.it/home/provisions-legislation/legislation/EC-and-international-legislation/transfer-of-data-towards-third-party-countries#.

The transfer of your personal data to countries that do not belong to the European Union and that do not ensure adequate levels of protection will be carried out only after the execution of specific agreements between Braccialetti Aua and these entities, establishing appropriate safeguards and guarantees for the protection of your personal data so-called "standard contractual clauses", also approved by the European Commission, or if the transfer is necessary for the conclusion and performance of a contract between you and Brainpull (for the registration to the Site or the use of services offered on the Site) or for the handling of your requests.

How long we keep the data
We keep your personal data for a limited period of time, which varies depending on the type of activity involved in processing your personal data.

After this period has expired, your data will be irreversibly deleted or otherwise anonymised.

Your personal data are stored in accordance with the terms and criteria set out below:

data related to users' requests: useful data will be kept until your request has been satisfied; 
data collected in the context of the use of services offered on brainpull.com: these data will be kept for no more than 12 months after brainpull.com has sent a notice for verifying your consent for said processing, or, in case of no verification communication, for no more than 12 months after consent to said processing; 
CV: for 12 months after receiving data 
used for commercial communication activities towards users who have given their express consent on brainpull.com: these data are stored until no more than 12 months after brainpull.com sends a notice for verifying the consent to said processing, or, in case of no verification communication, no more than 12 months after the consent to said processing; 
data provided for statistical research activities, opinion polls and market researches towards users who have given their express consent on brainpull.com: these data are kept for no longer than 12 months after brainpull. com sends a notice for verifying the consent to said processing, or, in case of absence of a such notice no longer than 12 months after the consent to such processing; 
in case of no express consent to the use of personal data with automated or non-automated profiling mechanisms, for personal data related to your navigation, such as the pages you visit and how you interact with the single page, i.e. traffic, to the extent strictly necessary and proportionate to ensure network and information security: no more than 60 months from the collection of the data;
 personal data relating to the activation and use of automated, or non-automated, profiling mechanisms that do not base decisions having legal effects and do not affect in a similar significant way the natural persons involved: these data are retained until no more than 12 months from the sending of a notice for verifying the consent to said processing by brainpull.com, or, in the absence of a verification notice, no longer than 12 months after the consent to such processing.
In any event, for technical reasons, the end of processing and the consequent definitive cancellation or irreversible anonymisation of the relevant personal data shall be final within thirty days of the aforementioned deadlines.

Withdrawal of consent, access to data and other rights

You may exercise your rights at any time with regard to the specific processing of your personal data by Braccialetti Aua. Please find below their general description and how to exercise them.

Accessing and amending your data: you have the right to access your personal data and to ask for them to be corrected, amended or supplemented with other information. If you wish, we will provide you with a copy of the data concerning you that we hold.
Revoking your consent: you may revoke at any time a consent you have given for the processing of your personal data in relation to the following activities: the fulfilment of your requests for information and assistance; for the performance of one of the services offered by brainpull.com; applying for a job position; carrying out promotional and commercial activities; carrying out statistical research, opinion polls and market research; activating and using automated or non-automated profiling mechanisms, which do not base decisions that have legal effects and do not significantly affect the individuals involved in a similar way. Upon receipt of your request, we will promptly cease the processing of your personal data on the basis of your consent, while different processing or any processing based on other grounds will continue to be carried out in full compliance with the applicable provisions.
Object to the processing of your data: you have the right to object at any time to the processing of your personal data carried out on the basis of our legitimate interest, explaining the reasons justifying your request; before granting your request, Braccialetti Aua will have to assess the reasons for your request.
Deleting your data: in the cases provided for by current legislation, you can request the deletion of your personal data. Once we have received and considered your request, if legitimate, we will promptly stop processing and delete your personal data.
Requesting to temporarily limit the processing of your personal data: in this case Braccialetti Aua will continue to store your personal data but will not process them, unless you request otherwise and without prejudice for any exceptions that are provided for by law. You can obtain the restriction of processing when you contest the accuracy of your personal data, when the processing is unlawful but you object to the deletion of your data, when we no longer need your data but you need it to exercise your right in court and when you object to the processing, during the period in which we assess the grounds for your request.
Request your data or transfer it to a party other than Braccialetti Aua ("right to data portability"). You can ask to receive your data that we process on the basis of your consent or on the basis of a contract with you in a standard format. If you wish, and where technically feasible, we may at your request transfer your data directly to a third party named by you.
In order to exercise some of your rights described above, you can send an email to privacy@braccialettiaua.com with "privacy" in the subject line.

In order to ensure that our users' data are not breached or used illegally by third parties, we will ask you for certain information to ensure your identity before we accept your request to exercise one of these rights.

Security Measures

We protect your personal data with specific technical and organisational security measures to prevent your personal data from being unlawfully or fraudulently used. In particular, we employ security measures that ensure: the pseudonymisation or encryption of your data; the confidentiality, integrity, and availability of your data as well as the resilience of the systems and services that process them; and the ability to restore your data in the event of a data breach. Furthermore, Braccialetti Aua undertakes to regularly test, verify and evaluate the effectiveness of the technical and organisational measures in order to ensure continuous improvement in the security of processing.

Complaints

If you believe that your personal data have been processed unlawfully, you may lodge a complaint with one of the relevant data protection supervisory authorities seeking the enforcement of the legislation on personal data protection.

In Italy, the complaint may be submitted to the Garante per la Protezione dei Dati Personali.

More information on the procedures to submit such complaint is available on the Guarantor's website at http://www.garanteprivacy.it.

Change to this notice

The constant evolution of our services may lead to changes in the characteristics of the processing of your personal data described herein. Consequently, this privacy policy may be from time to time subject to amendments and additions, which may also be required with regard to new legislation on the protection of personal data.

We therefore invite you to periodically check its contents. Wherever possible, we will try to inform you of any amendments made and their consequences.

The updated version of the privacy policy, in any case, will be published on this page, stating the date of its last update.

Legislatives references and usefull links

The processing of your personal data is carried out by Braccialetti Aua in full compliance with the relevant discipline provided for by Regulation (EU) 2016/679 General Data Protection Regulation, the Italian regulations on the processing of personal data and the provisions of the Italian Supervisory Authority (http://www.garanteprivacy.it).

Last update: 02/09/2018

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