The privacy of your Personal Data is important to Ubique S.r.l. and its related companies and affiliates (referred to collectively as “Ubique", "we" or "our”) and we are committed to ensuring that your Personal Data is handled responsibly, in accordance with the applicable data protection law.
DATA PROTECTION LEGISLATION
"Personal Data" is data relating to you from which you can be reasonably identified. Examples of Personal Data include your full name, postal address, email address and telephone number. We recognise that your Personal Data is valuable and process your information in accordance with the European Data Protection law (hereinafter jointly referred to as "Data Protection Legislation").
Ubique is responsible as data controller for the processing of your Personal Data collected on the Ubique website under the European Data Protection Legislation and the Australian requirements as applicable.
PERSONAL DATA THAT WE COLLECT AND HOLD
We collect Personal Data to allow us to provide you with services and deliver information on the products and/or services offered by us. We make sure that the Personal Data we collect from you is necessary for and directly related to this purpose.
The type of Personal Data that we collect from you, will vary depending on the circumstances in which we are dealing with you. This information may include:
Personal details about you such as your name, gender, date of birth, residential and business addresses, telephone numbers, email and other electronic addresses;
If you have registered on our website, we may collect any information from your browser and our servers that may be connected to the contact details you gave when you registered, such as username, password, profession, company, etc. Other details relating to your relationship and dealings with us, including if we deal with you in a capacity other than a customer (for example, if you have applied for a position with us, pre-employment history, income, results of aptitude and other tests, contact and emergency details).
Information that you voluntarily provide to us through your responses to competitions, surveys, search functions, questionnaires, feedback, ratings and reviews and the like.
Credit card information we collect from you will go directly to our processor or bank and no personnel of Ubique will have access to this data. If you choose to purchase a product from us, our third-party payment processors will collect your payment information, and none of our personnel will have access to this data.
As a general rule, we do not collect sensitive information about you, such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health or condition, sexual orientation and judicial or criminal records ("Sensitive Information"). However, in circumstances where we require Sensitive Information from you for a lawful purpose, for example for the purpose of providing our services to you, we will seek your consent to collect Sensitive Information prior to collecting it.
We collect such Personal Data from you in a number of ways, including:
directly from you, such as when you enter your personal details on our websites (for example during registration or application for products and services), when you provide information by phone or in documents such as an application form;
from our affiliated companies;
from your representatives;
from our agents or service providers when engaged by us to do so or by other third parties, such as from referees, to verify the information you have provided us or to assist us to locate or communicate with you from sources where you’ve made your information publicly available;
from credit-reporting and fraud-checking agencies and credit providers for credit related purposes such as credit worthiness, credit rating, credit provision and financing;
from our own records of your dealings with us; or
when legally required to do so.
We make sure that the way we collect data from and about you is lawful and fair in your circumstances.
We take all practical steps to ensure that you are informed of what data you are obliged to provide us, what data you may voluntarily provide us and what we may do if you do not provide us with data which you are obliged to provide.
PURPOSES FOR WHICH WE USE INFORMATION YOU PROVIDE US
This is information you give us when you enter your personal details on the Ubique website (for example during registration or application for products or services) or by contacting us via post, phone, e-mail or otherwise, in the context of your communication with Ubique. We will use your Personal Data to:
Identify you. We do this because it is in our legitimate interest to make sure that your enquiry is genuine and is not being made for fraudulent reasons or is spam. We may also do this because we may be subject to legal obligations which require us to confirm the details that you provide us with before entering into a relationship with you;
Create an account when you register with us. We will do this because it is in our legitimate interest to use your Personal Data to communicate with you, to respond to your requests and to develop the relationship between us in the context of establishing and operating your account. If you submit Personal Data comprising an email address to Ubique, we may send you product and/or service related emails (e.g. transactional emails, service and policy updates in respect of matters related to or arising from the use of this website) because it is in our legitimate interests to keep you informed of your account activities or service changes.
It may also be necessary for us to:
use your Personal Data to perform an agreement with you, where we would be unable to provide those services without that information;
use your Personal Data to comply with a legal obligation relating to how we manage our relationship with you;
provide, administer and manage services and carry out obligations arising from any contracts entered into between us, such as but not limited to online purchases. In these circumstances, we will use your Personal Data to perform an agreement with you because we would be unable to provide those services without that information;
monitor your use of the website to ensure that content from our website is presented in to the most effective manner, to view given your device and to help the further development of the website by compiling aggregate statistics about our users to analyse website usage. We do this because it is in our legitimate interests to understand user behaviour so that we can ensure that we present information on the website that is of most interest to users and to ensure that information is displayed to you correctly and in a user friendly way;
to enable Ubique to conduct research and/or analysis on the use of its website and to evaluate and improve the products and/or services offered by Ubique. We do this because it is in our legitimate interests to understand the trends in the use and popularity of our products and services so that we can adapt existing and offer new services based on this research and analysis;
conduct communications between you and Ubique and respond to feedback with reference to your needs and expectations of services and/or products offered by Ubique. We will do this because it is in our legitimate interest to use your Personal Data to communicate with you, to respond to your requests about the services and facilities you require and to develop the relationship between us in the context of your use of our website;
fulfil recruitment and staffing purposes. We will use your Personal Data to consider and decide how to respond to your enquiry because it is in our legitimate interests to use your Personal Data to consider whether we have any suitable job vacancies and to contact you about them. It may also be necessary for us to use your Personal Data to comply with a legal obligation relating to how we manage our business;
provide you with information related to Ubique including the products, services, news, events and other privileges, benefits and other advantages from time to time offered by Ubique, where you have opted in to receive this information.
When you opt-in to receive communications from us, you are giving your consent for your Personal Data to be used by us to contact you (depending on your selection) by email, direct mail and telephone, and to deliver personalized website experiences, to share information about relevant products and services, news and events in relation to Ubique's offering.
We shall not use your Personal Data for marketing communications unless we have received your consent. Your consent may be communicated to us without charge by checking the opt-in / consent box in this website.
If you subsequently decide that you do not want to receive correspondence from us about the services we could provide, you are entitled to withdraw your consent to us contacting you by clicking the "unsubscribe" link provided in a promotional email message, by amending your communication preferences. Withdrawing your consent will not affect our use of the Personal Data prior to you withdrawing that consent but it will mean that we will not be able to contact you about the services we may be able to offer you or your business in the future.
We will let you know where you must provide us with Personal Data in order to perform an agreement with you or your business or to comply with a legal obligation. If you do not provide us with the Personal Data in these circumstances, we may be unable to respond to your enquiry and/or engage in further communications with you.
INFORMATION WE COLLECT FROM THIRD PARTIES
We may use information provided to us by third parties that operate automated tracking technologies on third party websites, information you may have made publicly available or information provided by third party sources, such as marketing opt-in lists or data aggregators.
PURPOSES FOR WHICH WE USE INFORMATION WE AUTOMATICALLY COLLECT FROM YOU
When you visit the Ubique website, we may automatically collect information such as your IP address and browser type using cookies, log files, and pixel-tags (also called web beacons). This automatic data is primarily used for delivering and optimising services offered by us, such as:
authenticating your identity and confirming whether you are currently logged in as you move through the website. Your browser allows us to place some information (e.g., session based IDs and/or persistent cookies) on your computer's hard drive that identifies the computer you are using.
tracking your usage across our Ubique website in order to provide you with relevant, personalised content;
improving our services, whereby we may occasionally display different versions of content to you and measure your usage of our web site pages.
To the extent this information constitutes Personal Data, we use it to ensure that content from the Ubique website is presented in the most effective manner for you and your device because it is in our legitimate interest to improve our customers' online experience in relation to the Ubique website.
The following information sets out the types of cookies used on the Ubique website and provides detail about what they are used for. When you use the Ubique website for the first time, cookies which are essential to make the Ubique website operate (see those identified as "essential cookies" below) will have been set but other cookies will not have been set unless you agreed to those cookies being set at that time. If you have agreed to accept cookies then the Ubique website will remember this and continue to set cookies each time you visit. If you do not want cookies to be stored, then you may, via your browser, turn off certain cookies listed below individually or you can select the appropriate options on your web browser to delete some or all cookies. Please note, however, that if you block some or all cookies (including essential cookies) you may not be able to use or access all or parts of the Ubique website, such as being able to log on to member specific areas.
WHAT TYPES OF COOKIES DO WE USE?
We use a number of different cookies, outlined below:
First party cookies:
If you would like to disable cookies, you can set your web browser to reject cookies. However, if you disable the cookie function, you may not be able to access or receive all the information contained on the Ubique website.
CONSEQUENCES FOR YOU IF YOUR PERSONAL DATA IS NOT PROVIDED TO US
If you do not provide us with the Personal Data we ask for or the information provided is incorrect or incomplete, we might not be able to provide you with our products or services.
DISCLOSURES OF PERSONAL DATA TO THIRD PARTIES
However, we may disclose your Personal Data for the purposes listed above or as otherwise permitted by the Data Protection Legislation. By visiting the Ubique website, you agree to disclosures to the following third parties:
related entities, commercial partners (including parties with whom we have various types of commercial arrangements) and affiliates;
other companies and individuals which we employ to provide you promotional and informational offers on behalf of Ubique, such as email marketing services (e.g. analysing customer lists, deliverability statistics, opens and clicks), marketing assistance or consulting services. These third parties may have access to information needed to perform their function but can not use that information for any other purpose;
advertisers, which may collect aggregated statistics from the Ubique website;
payment processors who will collect your payment information if you choose to purchase a product from us;
credit reporting agencies and other financial institutions including our own bankers, service providers; our professional advisers, such as our accountants, auditors and lawyers, insurers and industry groups having a legitimate reason to receive such information.
other persons that we need to deal with in connection with engagement of staff (such as training or medical providers, insurers, next-of-kin, referees); and
STORAGE AND TRANSFER OF YOUR PERSONAL DATA TO OTHER COUNTRIES
Your Personal Data will be processed by Ubique within the European Union territory.
If for technical or operational reasons should be required to use entities located outside the European Union territory, as of now we inform you that these entities will be appointed as data controllers pursuant to GDPR, article 28 and the transfer of your Personal Data to those entities, with reference only to execution of specific processing activities, shall be regulated pursuant to chapter 5 of GDPR. Therefore, all required precautions will be adopted in order to ensure complete protection of your Persona Data considering that this kind of data transfer shall be based on: (a) decisions, by the European Commissions, of adequacy of third countries recipients; (b) adequate guarantees by the third entities recipients pursuant to GDPR, article 46; (c) the adoption of binding rules, also known as corporate binding rules.
Personal Data could be transferred in USA and UK to be stored in servers subject to signing contractual standards with servers’ providers and/or providers of services entrusted to third parties.
In any case you may request further details to the data controller whether your Personal Data have been processed outside European Union territory by requiring evidence of the specific precautions which have been adopted.
HOW PERSONAL DATA IS HELD AND PROTECTED
We will keep a record of the Personal Data that we receive from you in order to answer your query, respond to a request for more information about the services, or in response to an enquiry from one of our existing suppliers. Subject to legal requirements, we will only retain the Personal Data collected from a user for as long as the user’s account is active or has otherwise not been cancelled and the user has not requested that their Personal Data be deleted. We will retain Personal Data to fulfil the purposes for which we have initially collected it, unless otherwise required by law. All Personal Data will be retained only as necessary to comply with our legal obligations.
We will delete our copy of your Personal Data 7 years from the end of our contact with you or when we are no longer required by law to retain it (whichever is later), although we may retain a record of the existence of the relationship, to the extent and for so long as we are required to do so by law. For example, if you have contacted us to ask us for the processing of your Personal Data to be erased, we will retain a record of your request in order to ensure we comply with your wishes.
You should keep in mind that Internet transmissions (including emails) are never completely secure or error-free. As such, you should take steps to protect yourself, especially online and take special care in deciding which information you send to us via e-mail or other transmissions. Moreover, where you use passwords, ID numbers, or other special access features on the websites, it is your responsibility to safeguard them. You should choose a strong password, do not use the same password that you use on other websites and do not share your password with anyone else. Also remember to sign out of our websites and close your browser window when you have finished to ensure that others who may have access to your computer cannot access your personal information.
Pursuant to GDPR, article 15, you may access your Personal Data, apply for rectification and update, if incomplete o incorrect, apply for cancellation if their collection has been executed violating law or regulation as well as, for legitimate and specific reasons, oppose the processing of personal data.
In particular, here below you may find the rights which you may exercise, at any time, against the data controller:
Right of access: you will have the right, pursuant to GDPR, article 15, to obtain, by the data controller, confirmation as to whether or not your Personal Data are being processed and in this case, to obtain access to these Personal Data and to the following information: (a) purposes of the processing; b) categories of personal data concerned; (c) the recipients or categories of recipients to whom the data have been disclosed, in particular if the recipients are third countries or international organization; (d) when possible, the storage period of personal data or, if possible, the specific criteria used for the determination of this period; (e) the existence of the right to request from the data controller access to and rectification, erasure or restriction of data processing or the restriction of Personal Data processing or the right to oppose the data processing; (f) the right to lodge a complaint with a supervisory authority; (g) if the Personal Data are not collected from the data subject, any available information as to their source; h) the existence of an automated decision process, including profiling provided under GDPR, article 22, paragraphs 1 and 4 and, at least in this cases, significant information on the logic adopted, as well as the importance and the envisaged consequences from this processing for the data subject.
Right of rectification: you may obtain, pursuant to GDPOR, article 16, rectification of your Personal Data which are incorrect. Furthermore, considering purposes of data processing, you may obtain integration of your Personal Data which are incorrect, also submitting a supplementary statement.
Right of erasure: you may obtain, pursuant to GDPR, article 17, erasure of your Personal Data without undue delay and the data controller shall be obliged to erase your Personal Data, if even one of the following reasons exists: (a) the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) you have revoked the consent on the basis of which the processing of your Personal Data is allowed and there is no further legal basis for their processing; (c) you have objected the data processing pursuant to GDPR, article 21, paragraphs 1 or 2 and there is no further legitimate or prevalent reason for the execution of your Personal Data processing; (d) your Personal Data have been unlawfully processed; e) it is necessary to erase your Personal Data to fulfil a legal obligation provided by the European Union law or national law.
In certain cases, as provided by GDPR, article 17, paragraph 3, data controller is legitimated to not execute the erasure of your Personal Data if their processing is required, for example, to exercise the right to freedom of expression and information, to fulfil a legal obligation, for public interest reasons, for storage for public interest, for statistical purposes or for the purposes of historical or scientific research, to establish, exercise or defend a right in a legal claim pending before a court.
Right to restriction of data processing: you may obtain restriction of data processing, pursuant to GDPR, article 18, in one of the following cases: (a) you have disputed the correctness of your Personal data (the restriction will last for the period during which the data controller will verify the correctness of Personal Data ); (b) the data processing is unlawful but you objected the erasure of you Persona Data requiring only a restriction to the relevant use; (c) even if the data controller no longer needs them for the processing, your Personal Data are required to establish, exercise or defend a right in a legal claim pending before a court.; (d) you have objected the data processing pursuant to GDPR, article 21, paragraph 1, and you are waiting for verification of the prevalence, in comparison with yours, of legitimate reasons of data controller.
In case of restriction of data processing, your Personal Data shall be processed, except for the storage, exclusively with your consent or to establish, exercise or defend a right in a legal claim pending before a court or to protect rights of another data subject or in the public interest. In any case, we will inform you before a restriction is revoked.
Right to data portability: at any time, you may, request and receive, pursuant to GDPR, article 20, all your Personal Data processed by data controller in a structured format, of customary use and readable or request the transmission to other data controller without restrictions. In this case, you will provide to us the proper information for identification of the new data controller to whom you want your Personal Data are transferred also providing a written authorization.
Right to object: at any time, pursuant to GDPR, article 20, you may object the processing of your Personal Data for reasons connected to your particular situation, including profiling. Furthermore, at any time you may object the processing of your Personal Data if these are processed for purposes of direct marketing, including profiling if connected to the direct marketing. In these cases, we will refrain from further processing your Personal Data except if there are binding legitimate reasons required to establish, exercise or defend a right in a legal claim pending before a court, which prevail on your interests, rights and freedom.
Revocation of consent: if you gave your consent to the processing of your Personal Data for one or more purposes with reference to which your consent has been required, at any time you may revoke it, totally or partially, without prejudice of the lawfulness of the processing based on consent given before the revocation.
METHODS FOR THE EXERCISE OF THE RIGHTS
At any time, you may exercise your rights by sending an email to the following address:
We inform you that, in case of exercise of your rights, we could ask you to identify before starting the processing of your request.
Pursuant to GDPR, data controller is not authorized to charge any cost in order to fulfil one of the requests provided under this paragraph, unless they are manifestly unfounded or excessive or repetitive. In case the user requests more than one copy of its Personal Data or in case of excessive or unfounded request, Ubique may (a) charge a reasonable fee, taking into account the administrative cost incurred to fulfil the request or (b) refuse to fulfil the request. In these cases, Ubique shall inform the user of costs before starting the processing of the request.
IS IT POSSIBLE TO SUBMIT A COMPLAINT?
You may submit complaint to the Italian Supervisory Authority if necessary or, you may contact this Authority with reference to the exercise of your rights.
Without prejudice of any other administrative or judicial appeal, you have the right to submit complaint to the Italian Supervisory Authority if you believe that processing of your Personal data has been executed in violation of GDPR. Further information is available on www.garanteprivacy.it
In any case, Ubique would be informed of any reason of complaint and invites users to use all contact channels before appeal to the Italian Supervisory Authority, in order to prevent and settle potential disputes in a friendly e fast way, with highest confidentiality, reliability and courtesy.
If you wish to contact us about the privacy-related matters described above or find out more information about our privacy practices, please use the contact details below:
Via Rosmini 8, Milano 20154